S. Muralidhar, J.

1. This judgment is common to sixteen writ petitions filed under Article 226 of the Constitution of India by companies belonging to the Alcatel-Lucent group. Four of the writ petitions are by M/s. Alcatel-Lucent France (‘ALF’), five by M/s. Alcatel-Lucent Bell NV ('ALB'), five by M/s. Alcatel-Lucent Enterprise ('ALE') and the remaining two by M/s. Alcatel-Lucent Canada ('ALC'). The challenge in all these writ petitions is to the notices issued by the Income-tax Department (hereafter 'the Revenue') to each of the Petitioners under Section 148 of the Income Tax Act, 1961 ('Act') seeking to reopen the assessments for various Assessment Years ('AYs'). The orders rejecting the objections of the Petitioners to such reopening are also under challenge. Consequently, the questions that arise for determination are similar.

Facts concerning Alcatel-Lucent France

2. To begin with the Court proposes to discuss in some detail the facts concerning ALF. As already noticed, the facts concerning the other Petitioners are more or less similar, and will be adverted to in brief at the appropriate stage in this judgment.

3. ALF, a company incorporated under the laws of France, th