Dismissing the appeal of the revenue the Court held that the issuance of notice under section 148 of the Act and dropping of the proceedings after verifying the details are not administrative decisions. The decision to be taken before issuance of notice for reopening should be based upon cogent reasons and the Assessing Officer who issues notice should record his satisfaction and this cannot be termed as purely an administrative decision but there is a quasi-judicial application of mind required before issuance of notice under section 148 of the Act. Court also affirmed the view of the Tribunal  that  the shares were transferred only to comply with the legal requirements and the beneficial ownership was never transferred.  (AY.2001-02)