Section 127 of the Income Tax Act, 1961— Act, 1961 — Transfer of case—It is well settled that when a challenge is made against an order, all the grounds available and legally sustainable should be raised at the first instance, price meal raising of grounds one after another in successive writ petitions in respect of the very same challenge is not permissible. A careful perusal of section 127(2) (a) would show that only when those two Commissioners are in agreement, would the transferring Commissioner issue notice to the asseasee and pass order giving reasons that too after giving the asseasee a reasonable opportunity of being heard. The reasons states in the proceedings were in conformity with the show cause notice already issued and therefore,  the assessee was not entirely to state that the reasons stated were beyond the scope of the show cause notice — MRL Posnet P. Ltd. vs. Principal Commissioner of income tax [2019] 418 ITR 349(Madras)