I suppose if your relay is OOS for whatever reason and you need a transfer...
On the other hand, a M-T-M transfer scheme can be implemented with SEL relays and mirrored bits with a few serial cables.
The PLC route would need some loss of voltage sensing relays, Auto/Manual switches, associated wiring, etc. If the protection relays have enough available programmable push buttons & display points it is less wiring.
If this is a new installation / design either is probably just as easy. If you are trying to install into an existing location, consider that the protection may be disabled during installation and testing. One way or the other, the transfer scheme has to be wiring into the MTM trip / close scheme.
I would also consider the end user preference and comfort with pressing buttons on relays. Some non utility maintenance staff may be wary of touching a relay.