M.R. Shah, J.

1. Rule in each case, returnable forthwith. Learned counsel Shri Nitin K Mehta waives service of notice on behalf of the respondent-Revenue.

2. With the consent of the learned advocates appearing for and on behalf of the respective parties, these matters were heard together.

3. As common question of law and facts arise in this group of petitions and as such in respect of the same assessee, but with respect to different assessment years, all these petitions are disposed of by this common judgment and order.

4. In all these writ petitions preferred under Article 226 of the Constitution of India, the common assessee has challenged impugned orders passed by the respondent No. 1-Assessing Officer by which, in exercise of power under Section 142 [2A] of the Income-tax Act, 1961 [hereinafter referred to as, "the Act"], the Assessing Officer has directed the petitioner to get its accounts audited for Assessment Year 2009-2010, as a successor of erstwhile firm-Chanakya Infracon Private Limited [Special Civil Application No. 4619 of 2017]; for Assessment Year 2009-2010, as successor of erstwhile firm-Youngstar Infracon Private Limited [Special Civil Application No. 4613 of 2017]; for A.Y 2009-2010, as a successor of erstwhile firm-Chanakya Buildcon Private Limited [Special Civil Application No. 4614 of 2017]; and for A.Y 2009-10, as a successor of erstwhile firm-Takshashila Properties Private Limited [Special Civil Application No. 4620 of 2017].

5. The facts leading to the present Special Civil Applications, in nutshell, are as under :

5.1 That, in the case of erstwhile firms viz., Chanakya Infracon Private Limited; Youngstar Infracon Private Limited; Chanakya Buildcon Private Limited and Takshashila Properties Private Limited, the assessment proceedings for Assessment Year 2009-2010 were completed. That, pursuant to an order dated 22nd March 2011 passed by the High Court of Gujarat in Company Application No. 263 of 2011, five companies viz., Chanakya Buildcon Private Limited; Chanakya Infracon Private Limited; Takshashila Properties Private Limited; Takshashila Realities Limited and Youngstar Infracon Private Limited came to be amalgamated with Takshashila Gruh Nirman Private Limited. Messrs. Takshashila Gruh Nirman Private Limited is subsequently named as Takshashila Realities Limited. It appears that in case of transferee companies viz., Takshashila Gruh Nirman Private Limited; Chanakya Buildcon Private Limited; Chanakya Infracon Private Limited and Youngstar Infrastructure Private Limited, reassessment proceedings came to be initiated for A.Y 2009-2010. Notices under Section 148 of the Act came to be issued and served upon the respective assessees. The aforesaid transferee companies-original assessees preferred Special Civil Applications No. 13971 of 2016; 14018 of 2016; 14071 of 2016 and 14794 of 2016 before this Court challenging Notices under Section 148 of the Act and the reassessment proceedings. That, by a detailed judgment and order dated 5th December 2016, Division Bench of this Court, dismissed the said Special Civil Applications.

5.2 That thereafter, the petitioner herein-Takshashila Realities Private Limited has been served with a Notice under Section 142 [2A] of the Act and the petitioner, as the successor of firms viz., Chanakya Buildcon Private Limited; Chanakya Infracon Private Limited; Takshashila Properties Private Limited and Youngstar Infracon Private Limited was called upon to show cause why an order for special audit under Section 142 [2A] of the Act may not be passed. In the show cause notice, it was noted that the conversion of five firms into companies, after revaluation of land, merger of five companies with Takshashila Gruh Nirman Private Limited; later with issue of equity shares against the balance of revaluation credits at a premium; valuation of shares as Discounted Cash Flow method by estimating cash flows and adopting a random discounted rate for valuation, there is a complex web of t