Assessment transfer notices and reasoned orders can defeat a non-communication challenge when no objection is raised.

An assessment circle transfer under section 127(1) of the Income-tax Act was upheld where the assessees had been served notice, had notice of the hearing, but neither appeared nor objected to the proposed transfer. The order recorded reasons for the administrative transfer, and the Court treated quashing it solely for non-communication as an idle formality in those circumstances. The assurance that a copy of the reasoned order would be supplied further supported the validity of the transfer order, and the challenge failed.

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Issues: Whether an order transferring an assessee's assessment circle under section 127(1) of the Income-tax Act, 1961 could be invalidated for non-communication where the assessees had been served notice but did not appear or object.

Analysis: The transfer was preceded by notices to the assessees, who had notice of the hearing but remained absent and filed no objection to the proposed transfer. The order recorded reasons for the administrative transfer, and the Court noted that quashing it only for non-communication would be an idle formality in the circumstances. The Court also took note of the assurance that a copy of the reasoned order would be supplied to the petitioners.

Conclusion: The transfer order was not liable to be set aside on the ground of non-communication, and the challenge failed.

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