JUDGMENT : Prasanna Mukerji, J. 1. Regrettably the order under Section 127(2A) and Section 127(3) of the Income Tax Act, 1961 suffers from many infirmities. The assessment of the writ petitioners has been transferred from ACIT, Circle 45, Kolkata to DCIT/ACIT, Central Circle-I, Kanpur. 2. The reasons advanced by the Income Tax department are these. 3. A search and seizure operation under Section 132 of the said Act was conducted against M/s. Frost International Group of Kanpur. The writ petitioners are having "substantial involvement in terms of financial transactions" with Frost. Secondly, "coordinated investigation" is required of Frost as well as of the writ petitioners. Thirdly, the case of the writ petitioners is required to be centralised with the assessing officer of Frost. 4. Mr. Khaitan, learned Senior Advocate for the petitioners, submits that the case of the petitioners, as contained in their reply to the show cause notice, was not considered at all. According to him, the writ petitioners were only buyers of items from Frost and there was no other relationship. 5. Mr. Nizamuddin, learned Advocate for the revenue, submits that there are a lot of materials against the writ petitioners and that his clients should be allowed to file an affidavit to bring them on record. 6. In my opinion, the first and paramount the test before the Court when this kind of an order is challenged, is whether the order on the face of it can pass the test of legality. 7. When it was stated that the writ petitioners had financial transactions with Frost, some details of those transactions were required to be given in the transfer order. 8. When "coordinated investigation" was spoken of, the nature of investigation being carried out against Frost, the alleged nexus between Frost and the writ petitioners in relation to that investigation had to be stated in some detail. Thereafter, the need, if at all for coordinated investigation, would arise. 9. Unfortunately, the basic submission of Mr. Khaitan that his clients were buyers of goods of which Frost was the seller and that the writ petitioners had many such suppliers, was not even considered. If the relationship between the parties is of ordinary trading, there is no reason for clubbing together of their assessments, in my opinion. Something more has to be shown. 10. Inviting affidavits cannot improve the transfer order. 11. If the relationship between the parties is of ordinary trading, there is no reason for clubbing together of their assessments, in my opinion. Something more has to be shown. 10. Inviting affidavits cannot improve the transfer order. 11. Since the transfer order was passed on 17th March, 2014, the writ application filed on 12th June, 2014 and the same is being moved today, lam not passing any order for re-transfer of the files at the moment. 12. The order dated 17th March, 2014 is set aside with a direction upon the Commissioner to pass a fresh order, upon considering the submissions of the petitioner, by a reasoned decision in accordance with the above observations, within a period of eight weeks from the date of communication of this order. 13. The respondents will issue an additional show cause notice within two weeks of communication of this order giving all details as to why transfer is sought. The Advocate on Record for the petitioner will also be at liberty to write to the respondent authorities for any specific details that they want on the show cause or additional show cause notice. 14. The transfer of files will abide by the result of the adjudication to be made by the Commissioner. 15. In the facts and circumstances above, affidavits are not invited. The allegations contained in the writ petition are deemed not to be admitted. 16. This writ application is accordingly disposed of. Certified copy of this order, if applied for, be supplied to the parties upon compliance with requisite formalities. Application is disposed of.