On appeal by the Revenue  High Court dismissed the Department’s appeal from the order of the Tribunal quashing notices issued under section 148 of the Income-tax Act, 1961, holding  that while according sanction to reopen the assessment, the Joint Commissioner had only recorded “Yes, I am satisfied” and that the mechanical way of recording satisfaction was clearly unsustainable, on a petition by the Department for special leave to appeal to the Supreme Court, The SLP of revenue is dismissed. (AY 1-4-1998 to 12-12-2002)