Held that by the notice dated December 14, 2023, only three days’ time was provided to the assessee to respond thereto. The notice referred to the search and seizure action and the documents seized as a consequence thereof. It also referred to the interconnected nature of the documents. Conspicuous by its absence was any reference to the role of the assessee in this transaction. By contrast, the order referred to the assessee as one of the key persons. When these facts and circumstances were considered cumulatively, reasonable opportunity was not provided to the assessee. Hence the order for transfer of case was not valid.