JUDGMENT

Manmohan, J. (Oral)

C.M.No.37828/2021

Exemption allowed, subject to all just exceptions.

Accordingly, the application stands disposed of.

W.P.(C) No.12111/2021 & C.M.No.37827/2021

1. Present writ petition has been filed challenging the order dated 05th January, 2021 passed under Section 127 of the Income Tax Act, 1961 (hereinafter referred to as the `Act') and all consequent actions initiated pursuant to the said order. Petitioner also seeks directions to the Respondents to judiciously consider the objections filed by the Petitioner objecting to the transfer of jurisdiction under Section 127 of the Act.

2. Learned counsel for the Petitioner states that the impugned order is illegal since neither Petitioner's reply was considered nor any opportunity of hearing was given to the Petitioner before transferring the jurisdiction from Respondent No.3 to Respondent No.4. She states that Petitioner's case was transferred along with the PMC Group despite there being no linkage of the Petitioner-Trust with the said Group. She emphasises that the Petitioner- Trust has not received any donation from PMC Fincorp Group and/or has never entered into any financial transaction with the