Punjab & Haryana High Court Upholds Centralisation of Income Tax Assessment to Goa Under Section 127 IT Act; Holds Transfer Based on Interlinked Search Material and Public Interest Not Open to Interference
Case Name: Bhupinder Singh v. Principal Commissioner of Income Tax, Chandigarh and Others
Date of Judgment: 17 December 2025
Citation: CWP-29843-2025
Bench: Hon’ble Mr. Justice Deepak Sibal and Hon’ble Ms. Justice Lapita Banerji
Held: The Punjab and Haryana High Court dismissed a writ petition challenging the transfer of the petitioner’s income-tax assessment from Chandigarh to Panaji, Goa under Section 127(2) of the Income Tax Act, 1961. The Court held that transfer of jurisdiction is a machinery provision exercised for administrative convenience, coordinated investigation, and public interest. Where adequate opportunity of hearing is granted, reasons are recorded, and a clear nexus exists between the assessee and entities subjected to search and survey proceedings, the High Court will not interfere in exercise of its writ jurisdiction absent allegations of mala fides or violation of statutory safeguards.
Summary: The petitioner challenged an order passed by the Principal Commissioner of Income Tax transferring his assessment jurisdiction from Chandigarh to Panaji, Goa, contending that the alleged undisclosed cash transaction arising from sale of his company had no nexus with search proceedings conducted against the Blue Ocean group in Goa. He asserted that the inquiry against him could conveniently be undertaken at Chandigarh and that the transfer caused undue hardship and discrimination.
The High Court examined the statutory framework under Sections 124 and 127 of the Income Tax Act and reiterated that the power of transfer of cases is administrative in nature, meant to facilitate effective investigation and efficient tax collection. The Court placed reliance on authoritative Supreme Court precedents including Pannalal Binjraj, Kashiram Agarwala, Ajantha Industries, and K.P. Mohammed Salim, holding that while reasons and opportunity of hearing are mandatory for inter-state transfers, the scope of judicial review remains limited.
On facts, the Court noted that search and survey operations conducted against the Blue Ocean group revealed material linking the petitioner to undisclosed cash transactions exceeding ₹10 crores through WhatsApp communications and statements recorded during survey proceedings at the premises of a related distributor entity. The material suggested a deeper interlinkage between the petitioner, the distributor, and the entities under investigation, warranting coordinated assessment at a single jurisdiction.
The Court further noted that jurisdiction to assess the distributor entity had already been transferred to Goa and that proceedings relating to other key individuals involved in the transaction were also being centralised there. In such circumstances, centralisation of the petitioner’s assessment was found to be justified, consistent with CBDT circulars governing transfer of cases, and rooted in public interest.
Rejecting the plea of hardship, the Court observed that assessment proceedings are largely conducted through digital platforms and that individual inconvenience must yield to larger public interest in effective tax administration. In the absence of any allegation of mala fides, arbitrariness, or violation of natural justice, the Court declined to interfere.
Decision: The writ petition was dismissed. The order transferring the petitioner’s assessment jurisdiction from Chandigarh to Panaji, Goa was upheld as lawful, reasoned, and in consonance with Section 127 of the Income Tax Act.