Dismissing the petition the Court held that  the requirements under section 127(2) were fulfilled as proper opportunity had been granted to the assessee to represent his case and a reasoned order had been communicated. Upon perusal of the records it was clear that the Principal Commissioner had clearly delineated the reasons of the transfer under section 127 of the Act in the order for a detailed and co-ordinated investigation of the assessee. One could not say that the present transfer was based only on surmises and conjectures as it was evident that the name of the assessee had been taken by some persons on whom investigation, search and survey was carried out. Furthermore, the statement of certain persons also indicated that there was transfer of cash to the tune of almost Rs. 20 crores from the residence of the assessee at Delhi. It was clear that the present transfer was based on cogent material that required further investigation by the tax authorities. The argument of the assessee that he was willing to co-operate in the investigation, thereby negating the requirement of the transfer, was of no relevance as the officer conducting the co-ordinated search was best suited to investigate and carry out the assessment of the assessee. At the stage of passing an order under section 127, after considering objections of the assessee, the authorities are not required to give out the entire case of the tax authorities. Furthermore, though the assessments of some of the involved persons were complete, that could not itself be a bar for a transfer order under section 127 of the assessee’s assessment. Nor could the fact that he had not been subjected to any search or seizure be a bar to transfer. There was enough material garnered from other persons to establish a concrete nexus. The order of transfer was valid. (W.P.No. 3868 of 2022 dt. 6-1-2023.