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TMI Blog2025 (3) TMI 604X X X X Extracts X X X X X X X X Extracts X X X X ..... ations followed by agreement even between the Chief Commissioners. Thus, records substantially bear out that there were agreements between the Principal Commissioners inter se and the Chief Commissioners inter se. The other requirements of section 127 (2) were also complied with. Besides, in this case, we cannot lose sight of the fact that centralisation was deemed essential in matters belonging to the Pacific Group or in matters where parties had nexus with the evasion carried out by the Pacific Group, resulting in considerable loss of revenue to the Exchequer. Therefore, consolidation was necessary on merits, and transfers were ordered with a view to such consolidation. By attempting to elevate the plea now raised to the status of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... no agreement between officers of equal rank was neither raised nor decided. 4. Mr. Naniwadekar submitted that the records in the present case show some agreement between the Chief Commissioner and the Principal Commissioner who are officers of unequal ranks. He submitted that an agreement between officers of equal rank is a condition precedent for exercising of power under section 127 (2) of the IT Act. He further submitted that mere absence of disagreement between the officers of coordinate rank is not equivalent to an agreement as contemplated under section 127 (2) of the IT Act. In support of this contention, he relied upon Herambh Shelke v. ML Karmarkar [2018] 96 taxmann.com 308 (Bom)., and Noorul Islam Educational Trust v. Commissione ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the records show that the proposal for transfer was first received from the PCIT, Central -II, New Delhi, on 7 October 2022. Based on such a proposal, a show cause notice was issued by the PCIT, Mumbai, on 24 January 2023. After that, as discussed in our order dated 7 January 2025, there were consultations followed by agreement even between the Chief Commissioners. Thus, records substantially bear out that there were agreements between the Principal Commissioners inter se and the Chief Commissioners inter se. The other requirements of section 127 (2) were also complied with. 9. Besides, in this case, we cannot lose sight of the fact that centralisation was deemed essential in matters belonging to the Pacific Group or in matters where parti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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