Held, dismissing the appeal the Court held that in the writ petition elaborately considered the facts and had upheld the order of transfer of case under section 127. The assessee was precluded from stating that the notice was coloured on facts. The notice dated January 11, 2022 issued by the Department disclosed the reasons for proposed transfer of case and the assessee had submitted his response as to how those reasons were not germane for exercise of jurisdiction under section 127. The assessee had been afforded effective opportunity to place all materials including an opportunity of personal hearing which had been availed of. After considering the response given by the assessee, the Principal Commissioner had passed the order of transfer dated February 23, 2022 with elaborate reference to all the factual details of the seized documents, recorded statements of parties indicating that unaccounted money was transferred from the assessee’s official residence at Delhi. The source of such money was required to be properly established and could only be identified by proper investigation and assessment. Further the claim of the assessee that such transactions were not linked to his personal income account could not be taken at face value without proper investigation and assessment. Therefore, the authority had opined that the Assessing Officer entrusted with the assessment of all other parties involved in the unaccounted money transactions was the most suitable Assessing Officer to complete the assessment as he was aware of the whole picture of the case and could do justice to the Revenue as well as to the assessee. Upon appreciation of the facts, the onus on the Department to justify the order of transfer had been proved. While examining the correctness of the administrative action, the court could not do the role of an Assessing Officer which was not permissible in a writ proceeding. The factual details which were set out in the court’s order were to justify the order of dismissal of the writ petition and could at best be construed to be reasons for refusing to exercise jurisdiction to interfere with the order of transfer and nothing more. The findings rendered therein were only prima facie findings and they could never cause any dent upon the ultimate decision which the Assessing Officer would take after considering the relevant facts and documents furnished by the assessee. There was no material on record to hold that the assessee was only a witness, and such a contention, being self serving was rejected. On account of the facts that the assessee in the writ petition had sought to justify his contention on the reasons recorded, this had necessitated the Department to bring facts on record and the assessee having invited such a response could not raise any complaint in this regard. The court was required only to consider as to whether there were grounds for transfer as emanating from the reasons recorded and there were adequate reasons. The facts that had emerged had showed that there were sufficient reasons assigned in the order of transfer of case. The sufficiency or insufficiency of such reasons were beyond the pale of adjudication in the present litigation, lest it might prejudice the assessee. There was no challenge to the decision-making process. The plea of mala fides had not been pleaded or proved. The plea of inconvenience had been found to be not tenable. Therefore, there was no good ground to interfere with the administrative order of transfer which was upheld. The Court also observed that the assessee has no right to be assessed under the Income-tax Act, 1961 in a particular area or locality. An order of transfer is purely in the nature of an administrative order passed for consideration of convenience of the Department and no possible prejudice can be involved when the cases have been transferred under section 127.Relied on  Pannalal Binjraj v. UOI (1957) 31 ITR 565 (SC),  Kashiram Aggarwalla v. UOI (1865) 56 ITR 14 (SC).(M.A.T.No.40 of 2023 and C.A.Noo. 1 of 2023 dt. 10 -2 -2023)