Centralised investigation power upheld where transfer was based on stated reasons and personal hearing would be futile.

The note examines validity of transferring a taxpayer's case to a central circle for coordinated investigation under the Income-tax Act, focusing on use of transfer power in the context of multiple connected search and survey operations and the sufficiency of the show-cause notice. It records that the transfer was based on stated reasons of centralisation to enable coordinated analysis of seized material and that requiring a personal hearing was unnecessary where it would be a useless formality because the notice's reasoning would not be altered; the challenge to the transfer was dismissed.

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Issues: (i) Whether the transfer of the petitioner's case from Central Circle-2, Bhubaneswar to Central Circle-1, Bhubaneswar under Section 127 of the Income-tax Act, 1961 for centralized/coordinated investigation was valid.

Analysis: The Court examined the statutory power under Section 127 of the Income-tax Act, 1961 to transfer cases for coordinated investigation in the context of multiple connected search and survey operations carried out under Section 132 and Section 133A of the Income-tax Act, 1961. The Court considered whether the show-cause notice dated 26.10.2023 provided reasons for proposed centralization and whether personal hearing was a necessary precondition where the result of such hearing would not alter the outcome. The Court applied the principle that courts need not insist on compliance with a formal hearing where it would be a useless formality and noted that the notice specified centralisation for coordinated investigation and detailed analysis of seized material.

Conclusion: The transfer under Section 127 of the Income-tax Act, 1961 for centralized/coordinated investigation was valid; the challenge to the transfer is dismissed and the petitioner's writ petition is dismissed (decision is against the petitioner and in favour of the Revenue).

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