Vibhu Bakhru, J.

1. The Petitioner, Adobe Systems Incorporated (hereafter the 'Assessee'), has preferred the present petitions under Article 226 and 227 of the Constitution of India, impugning three separate notices dated 30th March, 2011 (hereafter “the impugned notices”) issued under Section 148 of the Income Tax Act, 1961 (hereafter the “Act”) for Assessment Years (AYs) 2004-05, 2005-06 and 2006-07 respectively. The Assessee further impugns three separate orders dated 8th March, 2013 (hereafter “impugned orders”) passed by the Assessing Officer (hereafter “the AO”) rejecting the objections raised by the Assessee against the assumption of jurisdiction under Section 148 of the Act.

2. Briefly stated, the controversy in these petitions involves the question whether Adobe Systems India Private Limited (an Indian subsidiary of the Assessee and hereafter referred to as “Adobe India”) could be considered as its Permanent Establishment (PE). And if so, whether any part of the Assessee's income, could be attributed to such PE in respect of the activities carried out by Adobe India, income from which had been subjected to transfer pricing scrutiny/adjustment.

2.1 The Assessee dispu