Sec. 127 of Income Tax Act, 1961—Transfer of Case—An agreement between the two jurisdictional authorities is an essential pre-requisite to be complied with to transfer a case between them and in case of absence of such agreement, the provision of clause (b) of Section 127(2) is to be complied with for passing of an order of transfer where the Assessing Officer or Assessing Officers from whom the case is to be transferred and the Assessing Officer or Assessing Officers to whom the case is to be transferred are not subordinate to the same Principal Director or Director General or Principal Chief Commissioners or Chief Commissioners or Principal Commissioners or Commissioners. A show cause notice must convey the reasons for the proposed transfer of the case so that the assessee could make effective representation with reference to the reasons set out in the notice and a notice issued under Section 127 must prima facie show due application of mind and reasons must also be disclosed so that an effective opportunity is provided to the affected party to respond to the notice and as there was no reflection of these twin reasons in the notice and the reason as to why all the cases could not be clubbed under one ITO at Guwahati, the impugned orders of transfer of cases of the petitioner under Section 127 (2) were quashed—  M.K. Rajendran Pillai vs. Pr. CIT [ 2020] 421 ITR 274 (Gauhati)