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The impugned order came to be passed on 19-2-2019 and till the issuance of the assessment notices dated 15-7-2019 under section 153A of the Act, the petitioner did not challenge the order of transfer and there is no explanation for the delay in challenge. Hence, the petitioner is barred from challenging the same in exercise of jurisdiction by a new authority and this Court need not exercise the extraordinary jurisdiction under Article 226 of the Constitution to interfere with the impugned order. Though the other grounds raised by the petitioner have also no merit-acceptance, without delving further into those grounds, this Court is of the view that this writ petition is liable to be dismissed on these grounds.

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Sec. 127 of the Income Tax Act, 1961- Transfer of case - Where assessee did not challenge the order of transfer of its case at the earliest letting all believe that such transfer was accepted, assessee should be barred from challenging the same on exercise of jurisdiction by a new authority. - V.V. MINERALS V/s PR. CIT - [2020] 315 CTR 696 (MAD)

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