JUDGMENT :

SUDHANSHU DHULIA, J.

Heard Dr. Ankit Todi and Ms. P.S. Chakraborty, learned counsel for the appellant. Also heard Mr. S. Sarma, learned senior standing counsel, Income-tax, appearing for the respondents.

2. All these writ appeals have been filed by the writ appellant-petitioners. against a common judgment and order dated 25.9.201stpassed by the learned Single Judge in a batch of writ petitions, viz., WP(C) No. 33(K)/2019, WP(C) No. 34(K)/2019, WP(C) No. 35(K)/2019, ‘WP(C)’ No. 36(K)/2019, WP(C) No. 37(K)/2019, WP(C) No. 38(K)/2019 and WP(C) No. 39(K)/2019. In these writ petitions the petitioner in WP(C) No. 34(K)/2019 is a son of the petitioner in WP(C) No. 33(K)/2019. The petitioner in WP(C) No. 35(K)/2019 is also a son of the petitioner in WP(C) No. 33(K)/2019. The petitioner in WP(C) No. 36(K)/2019 and the petitioner in WP(C) No. 39(K)/2019 are the wife and the daughter respectively, of the petitioner in WP(C) No. 33(K)/2019. The petitioner in WP(C) No. 37(K)/2019 is a partnership firm, which is represented by one of its partners, who is the petitioner in WP(C) No. 35(K)/2019. The petitioner in WP(C) No. 38(K) is a private limited company, which is represented by one of its Directors, who is the petitioner in WP(C) No. 36(K)/2019. All the petitioners are the members of one family.

3. Presently, we have before us five writ appeals, arising out of the order dated 25.9.2019, passed by the learned Single Judge in WP(C) No. 33(K)/2019, WP(C) No. 34(K)/2019, WP(C) No. 35(K)/2019, WP(C) No. 36(K)/2019, WP(C) No. 37(K)/2019, WP(C) No. 38(K)/2019 and WP(C) No. 39(K)/2019.

4. Sri M.K. Rajendran Pillai is the promoter of M/s. Sreevalsam Group. Sri Arun Raj Pillai is the appellant in WA No. 44/2020 and Sri Varun Raj Pillai is the appellant in WA No. 39/2020. WP(C) No. 36(K)/2019 was filed by Smt. Valsala Raj Pillai, who is the wife of Sri M.K. Rajendran Pillai and the appellant in WA No. 40/2020. WA No. 41/2020 has been filed by Smt. Pooja Raj Pillai, i.e., the petitioner in WP(C) No. 39(K)/2019, who is the daughter of Sri M.K. Rajendran Pillai. Since the subject-matter involved in all these appeals is common, it is being decided by this common order.All the same, for the sake of convenience the facts we would refer to pertains to WP(C) No. 33(K)/2019, which is now WA No. 45/2020, which is the writ petition and writ appeal respectively filed by Sri M.K. Rajendran Pillai.

5. The case of the petitioner/assessee before the learned Single Judge was that he has business interest in Kollam, Kerala as well as in Dimapur, Nagaland, but most of the time he resides in Dimapur, Nagaland. The Revenue, in exercise of its power under section 127 of the Income-tax Act, 1961, in order to centralise the process for assessment, has transferred the case from Dimapur, Nagaland to Kollam, Kerala vide the’ impugned order dated 18.7.2018. It was alleged by the petitioner that this has been done without proper notice to the assessee-petitioner assigning any reasons as to why such transfer was being made and it is in violation of section 127 of the Act. Further, since the notice itself was not served upon the petitioner as was liable to have been done under the provisions contained in the Income-tax Act and the rules framed therein, it is also violative of section 282 of the Act as well as rule 127 of the Income-tax Rules, it was alleged.

6. The brief facts of the case, however, are that in terms of section 132 of the Act, search and seizure was conducted by the Revenue on 8.6.2017 at various business as well as residential premises of the petitioner in Kerala. The petitioner/writ appellant is the promoter of a group, which we shall for the sake of convenience mention here as “M/s. Sreevalsam Group”. It was in this search and seizure operation that it was discovered that Sri M.K. Rajendran Pillai [petitioner in WP(C) No. 33(K)/2019] is the promoter of M/s Sreevalsam group and his wife, Smti Valsala Raj Pillai, their two sons and a daughter, who were all th