Income-tax case transfer under Section 127 upheld where coordinated investigation and search-related circumstances justified Central Circle assessment.

Transfer of an income-tax case under Section 127 was upheld because the search-related circumstances and CBDT guidelines supported coordinated investigation in the Central Circle, and no compelling ground to invalidate the transfer was shown. The challenge based on alleged absence of reasons and the availability of faceless assessment at Theni was rejected, as the Court accepted that the transfer was justified by the need for coordinated inquiry. The writ petition was dismissed and the transfer order sustained.

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Issues: Whether the transfer of the petitioner's income-tax case under Section 127 of the Income-tax Act, 1961 to the Central Circle at Kochi was liable to be set aside for want of reasons and alleged arbitrariness.

Analysis: The challenge centred on the absence of reasons in the transfer order and the plea that the assessment could continue at Theni in a faceless regime. The opposing case was that a search had been conducted, cash had been seized in Kerala, and the matter fell within the CBDT guidelines requiring assessment in the Central Circle for coordinated investigation. The Court found that the petitioner had not shown any compelling ground to interfere with the transfer and accepted that the search-related circumstances and applicable guidelines justified moving the case to the Central Circle.

Conclusion: The transfer order was upheld and the writ petition was dismissed.

Final Conclusion: The impugned transfer of the case for coordinated investigation was sustained, and the petitioner obtained no relief.

Ratio Decidendi: A transfer of assessment under Section 127 of the Income-tax Act, 1961 will not be interfered with where the search-related circumstances and applicable CBDT guidelines support coordinated investigation and no compelling ground to annul the transfer is shown.

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