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JUDGMENT M.S. Sanklecha, J.-By this petition under article 226 of the Constitution of India, the petitioner challenges : (a) Order dated August 31, 2012, passed under section 127 of the Income-tax Act, 1961 ("the Act"), transferring with effect from August 31, 2012, the petitioner's papers and proceedings (case) under the Act from the Deputy Commissioner of Income-tax, Mumbai, to the Deputy Commissioner of Income-tax, Hyderabad ; and (b) Four notices dated July 23, 2013, issued under section 148 of the Act by the Deputy Commissioner of Income-tax, Hyderabad, seeking to reassess the petitioner for the assessment years 2009-10, 2010-11, 2011-12 and 2012-13. 2. Briefly, the facts leading to this petition are as under : (i) The petitioner is a joint venture between one Patel Engineering Ltd. and K. N. R. Construction Ltd. each having 50 per cent share. The petitioner is assessed as an association of persons (AOP) under the Act at Mumbai since the assessment year 2002-03. The petitioner is engaged in the business of development of infrastructure facilities/projects like construction of roads, highways, etc. (ii) On August 28, 2012, the petitioner received a notice dated August 22, 2012, from the Commissioner of Income-tax, Mumbai. By the above notice, the petitioner was called upon to show cause why the petitioner's assessment should not be centralised with the Deputy Commissioner of Income-tax at Hyderabad, for the purposes of better investigation, co-ordination and in public interests. The above notice fixed the personal hearing on August 29, 2012. (iii) On August 29, 2012, the petitioner filed its reply to the show-cause notice, opposing the transfer of its case from Mumbai to Hyderabad. The petitioner pointed out that its management is in control of Patel Engineering Ltd. which is assessed in Mumbai. Besides, it also forms part of the consolidated audited accounts of Patel Engineering Ltd. Moreover, it was submitted that accounts and all related documents of the association of persons are maintained in Mumbai and assessing them at Hyderabad would cause great inconvenience and difficulties to the petitioner. In view of the above, it was submitted that the…

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