( 1 ) THESE are two connected appeals, one made by the Revenue and the other made by the assessee. The Revenue has challenged the impugned order on the ground that the learned single Judge has granted leave in terms of prayer (1) of the writ petition, that is, the stay of operation of the order appointing special auditor. The assessee has challenged the impugned order dated May 4, 1999, on the ground that before issuing of notice under Section 142 (1) of the Income-tax Act, 1961, the Income-tax Officer has not applied his mind, and that it is not possible to comply with the direction referred to in the said notice.

( 2 ) AS both the appeals are connected, whether the accounts of the assessee be audited by the special auditor appointed under Section 142 (2a) of the Act or whether the Assessing Officer should look into the accounts himself, in case the special auditor is not permitted to audit the account and the Assessing Officer is also not in a position to look into the accounts of all the branches when the assessee is not in a position to produce all the books of account maintained by all the 43 branches of the assessee, then whether it can be said that the impu