The assessee an apex body of the Co-operative, came into existence by an order of the State Government to facilitate collection, storage, processing and disposal of specified forest produce within the periphery of the State of Chhattisgarh and the society was entitled for a commission of Re. 1 per annum for the aforesaid services rendered by it as an agent of the State Government of Chhattisgarh.The Commissioner exercised revisionary jurisdiction under section 263 against the assessee on ground that the Assessing Officer had not conducted proper enquiry regarding genuineness of the contention made by the assessee. The Commissioner set aside the assessment order and remanded the matter back to the Assessing Officer for fresh adjudication of the issues discussed by conducting necessary enquiries in this case and framing fresh assessment order after affording adequate opportunities to the assessee. On appeal, the Tribunal upheld the order passed by the Commissioner. On appeal the Court held that

The reasons for satisfaction or non-satisfaction are required to be recorded. In the instant case, after going through order, which is the substratum of the entire issue, it is manifest that the said procedure has not been followed.  Accordingly  the appeal is allowed and question of law is answered in favour of the assessee and case is remanded back to the Principal Commissioner to reconsider the reply and the documents of assessee.