S. Muralidhar, J.

1. These are three writ petitions by Avtec Limited which challenge the notices dated 31st March, 2015 issued to it by the Respondent Deputy Commissioner of Income Tax, Circle-1 [hereinafter referred to as the Assessing Officer (‘AO’)] under Section 148 of the Income Tax Act, 1961 and the order dated 11th January, 2016 passed by the AO disposing of the Petitioners objections thereto.

2. The aforementioned notices were issued seeking to reopen the assessments of the Petitioner for Assessment Years (‘AYs’) 2008-09, 2009-10 and 2010-11.

3. The background facts are that the Petitioner is engaged in the business of manufacturing and selling of automobiles, power trains and power shift transmissions along with their components.

4. The Petitioner entered into a Business Transfer Agreement (‘BTA’) with Hindustan Motors Ltd. (‘HML’) on 19th February, 2005. In terms thereof the Petitioner took over the business from HML. Expenses in the sum of Rs. 84,38,357 pertaining to professional and legal charges were paid in relation to the taking over of the business from HML including drafting and due diligence and other contracts reimbursed to HML and ACTIS India and South Asia F