Order

REPORTABLE

PER, HON’BLE MR. RAVI CHIRANIA, J.

1. The present petition is the second round of litigation. In the earlier round, petitioner approached this Court with the similar grievance challenging the notice issued under Section 127 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’ for short). The co-ordinate Bench of this Court, in the previous round of litigation of the petitioner, passed a reasoned order dated 20.07.2022. The relevant paragraphs of the order dated 20.07.2022 passed in D.B. Civil Petition No.6847/2021 titled as ‘Murliwala Agrotech Pvt. Ltd. Vs. Union of India & Ors.’ are as under:

“We have given our thoughtful consideration to the submission advanced at bar and have gone through the impugned order, the statutory provision and the judgments cited at bar.

At the outset, we may state here that Section 127(1) of the Income Tax Act, which deals with powers of the competent authority to transfer the a