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Petition under articles 226 and 227 for quashing tax order and transfer of assessment proceedings. Analysis: The petitioner, a private limited company, sought to transfer its assessment file from Rohtak to Ahmedabad due to operational convenience. The company's operations had shifted to Ahmedabad after the closure of its unit in Hissar. The request for transfer was made to the Deputy Commissioner of Income-tax, Chief Commissioner of Income-tax, and the Central Board of Direct Taxes. The Central Board of Direct Taxes declined the request citing reasons such as the company's registered office still being in Hissar, administrative considerations, and sales tax exemption obligations in Haryana. The petitioner challenged this decision under Section 127 of the Income-tax Act, 1961, which allows for the transfer of proceedings. The court found no merit in the challenge, emphasizing that the decision to decline the transfer request was an administrative act. The court distinguished a previous Bombay High Court decision regarding the necessity of providing an opportunity for explanation, stating that the petitioner's application had been duly considered and rejected with reasons provided. Given that the petitioner had not taken steps to change its registered office and the search and seizure operations were conducted in both Hissar and Ahmedabad, the court upheld the Central Board of Direct Taxes' decision as reasonable and dismissed the writ petition. This judgment addresses the legal principles surrounding the transfer of tax assessment proceedings, emphasizing administrative discretion and the need for valid reasons to support such decisions. It underscores the importance of considering operational convenience, registered office location, and other relevant factors in determining the appropriate jurisdiction for tax assessments. The court's analysis provides clarity on the application of Section 127 of the Income-tax Act, 1961, and highlights the significance of providing sound justifications for administrative decisions in tax matters.
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