Transfer of assessment proceedings for coordinated investigations and administrative convenience upheld where procedural safeguards and factual links exist.
The judgment explains that transfers of assessment proceedings pursuant to the statutory transfer power may be justified for coordinated enquiries and administrative convenience, provided the decision is not capricious or mala fide. Authorities must afford an opportunity to be heard and consider objections; where factual indicia exist - for example, disclosed transactions such as unsecured loans with searched persons - centralisation can be sustained. The convenience of the assessee is relevant but subservient to effective adjudication and tax collection, and transfers supported by procedural compliance and factual nexus are not arbitrary.