The satisfaction has to be recorded with objectivity and objective material and not in a mechanical manner- an analysis in view of law laid down by the Supreme Court in case of Goenka Lime and Chemicals Ltd and related Judgments of High Courts, in relation to reassessment. https://www.taxtmi.com/article/detailed?id=6610 Recorded satisfaction required for initiating actions must reflect an independent application of mind and objective material; a mechanical or formulaic endorsement by a senior officer without stated reasons is invalid. In reassessment under section 148 the High Court quashed a notice where the JCIT simply recorded "Yes, I am satisfied," and the Supreme Court dismissed the revenue's appeal, confirming that supervisory satisfaction must be reasoned and supported by material. Taxpayers should demand copies of recorded reasons and may challenge proceedings lacking such objective recorded satisfaction. en-us Fri, 01 Jan 2016 10:38:16 +0530 Fri, 01 Jan 2016 10:38:16 +0530 TaxTMI RSS Generator The satisfaction has to be recorded with objectivity and objective material and not in a mechanical manner- an analysis in view of law laid down by the Supreme Court in case of Goenka Lime and Chemicals Ltd and related Judgments of High Courts, in relation to reassessment. https://www.taxtmi.com/article/detailed?id=6610 Recorded satisfaction required for initiating actions must reflect an independent application of mind and objective material; a mechanical or formulaic endorsement by a senior officer without stated reasons is invalid. In reassessment under section 148 the High Court quashed a notice where the JCIT simply recorded "Yes, I am satisfied," and the Supreme Court dismissed the revenue's appeal, confirming that supervisory satisfaction must be reasoned and supported by material. Taxpayers should demand copies of recorded reasons and may challenge proceedings lacking such objective recorded satisfaction. Articles Income Tax Fri, 01 Jan 2016 10:38:16 +0530 https://www.taxtmi.com/article/detailed?id=6610