Centralisation of group assessments upheld where coordinated investigation was needed and no mala fides were shown.

Centralisation of group assessment cases was upheld under the Income-tax Act where incriminating material was found across different premises and a coordinated investigation was required. The HC applied the principle that transfer under Section 127 is justified when a unified assessment exercise is necessary and no mala fides are shown. On that basis, the challenge to the transfer and centralisation order failed, and the Revenue's action remained undisturbed.

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Issues: Whether the centralisation and transfer of assessment cases of group entities under Section 127 of the Income-tax Act, 1961 was liable to be interfered with.

Analysis: The appeals were identical to an earlier batch in which the same issue had been decided. The governing principle applied there was that, where incriminating material is seized from different premises of a group of concerns and coordinated investigation is required, centralisation of the cases at one place is justified under Section 127. In the absence of any mala fides, and in view of the need for a unified and coordinated assessment exercise, no infirmity was found in the transfer order.

Conclusion: The challenge to the transfer and centralisation of assessment cases was rejected and the appeals failed.

Final Conclusion: The transfer of the assessees' cases for centralised assessment was upheld, leaving the Revenue's action undisturbed.

Ratio Decidendi: Centralisation of group assessment cases under Section 127 of the Income-tax Act, 1961 is valid where it serves coordinated investigation and no mala fides are shown.

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