large number of transactions inter se vide which the tax had been evaded and that the petitioner was a key associate. Merely because the parties were doing business in the normal course inter se, would not be a ground as such to transfer the assessment in the absence of any major financial nexus, as such, a ground would result in transferring other assessments of assessees who were doing business with the NCG. The reasoning, thus, which has been resorted to by respondent no. 1 cannot be held to be justified in any manner as the serious rights of the petitioner are involved as assessment is to be transferred for all purposes to a far off place to its detriment. In similar circumstances, a Single Bench of this Court in Rajesh Mahajan's case (supra) has held that even if the transferee is one of the Directors, it was not a valid justification for the transfer of income tax proceedings. Firstly, it is essential, that the show-cause notice issued under Section 127 of the Act, discloses to the assessee the reasons/basis of the contemplated action in terms of the mandate of the rules of natural justice. Exceptions to this essential ingredient would be the same as the exceptions to the rules of natural justice. Secondly, an assessee has the right to file objections on the receipt of a show-cause notice issued under Section 127 of the Act. In the absence of such liberty, the assessee cannot be stated to have been afforded a "reasonable opportunity" as is contemplated by the aforesaid provision. Thirdly, the reasons recorded in the final order passed under Section 127 of the Act (by which the concerned/competent authority decides to execute the proposed action contemplated in the show-cause notice), must not only take into consideration the objections raised by the assessee, but the reasons recorded in the order must also have a direct nexus/bearing to the object
