Allowing the petition the Court held that the expression used in clause (a) to sub-section (2) is “agreement” ; “agreement” per se would mean that the concerned parties have to agree to a specific course of action. Furnishing a proposal may not amount to an agreement of the designated higher authorities as contemplated under clause (a) to sub-section (2) of section 127 . It was quite evident that before passing the order no opportunity of hearing was granted to the assessees. Hearing was granted after the decision was taken culminating in the second order. That apart, from the second order it was discernible that there was no agreement between the two jurisdictional Principal Commissioners to transfer assessment jurisdiction from Mumbai to Kochi. Evidently, the procedure prescribed under section 127(2)(a) of the Act had not been complied with. The order of transfer was not valid.