Recorded statutory satisfaction is essential before filing an appeal; mere approval of draft grounds is insufficient.

Where a statute requires a recorded satisfaction or opinion before an appeal is filed, mere approval of draft grounds is insufficient. The note sheet here showed only that the draft appeal was placed for approval; it did not record any independent consideration by the Commissioner on the legality or propriety of the impugned order, nor compliance with the statutory mandate for authorising the appeal. On that basis, the Revenue's appeal was held not maintainable because the statutory pre-condition for filing had not been met.

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Issues: Whether the Revenue's appeal was competent in the absence of a recorded opinion by the Commissioner satisfying the statutory requirement for filing an appeal.

Analysis: The note sheet produced by the Revenue merely showed that the draft grounds of appeal were placed for approval. It did not record any independent opinion of the Commissioner on the legality or propriety of the impugned order, nor did it demonstrate compliance with the statutory mandate governing approval for appeal.

Conclusion: The statutory requirement was not fulfilled, and the Revenue's appeal was not maintainable.

Ratio Decidendi: Where the statute requires a recorded satisfaction or opinion before an appeal is filed, a mere approval of draft grounds without such recorded consideration does not satisfy the mandate and renders the appeal incompetent.

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