Aditya Tripathi v. PCIT (2022) 287 Taxman 144/214 DTR 201/326 CTR 833 (MP)(HC)

S. 127 : Power to transfer cases-Transfer from Bhopal to Hyderabad-Transferred for consolidating records of principal contractors and sub-contractor-In public interest for a lawful search operation-Transfer is valid. [Art. 226]

Assessee challenged transfer order on ground that there was variance in reasons assigned by revenue in show cause notice and impugned order of transfer, thus, breach of reasonable opportunity.   Dismissing the petition the Court held that the assessee knew that case was being transferred for consolidating records of principal contractors and sub-contractor (assessee) at one place (Hyderabad), thus principle of audi alteram partem stood complied with by implication and ground of variance did not actually exist.