Allowing the petition the Court held that the show-cause notices did not disclose any facts regarding the steps taken by the Revenue to recover tax dues from the assessee-company and the order did not record any of the material which formed the basis for the Assessing Officer to conclude that all steps had been taken to recover the tax dues from the company. Further, it did not refer to the Assessing Officer’s subjective satisfaction based upon the material before it, to conclude that all steps had been taken to proceed against the company and such steps had failed. Accordingly due to failure to record the satisfaction, Show-cause notices and order quashed.  Followed ,Vanraj V. Shah v. Dy. CIT & Anr. (2019) 181 DTR (Bom) 5, Rajendra R. Singh v. Asstt. CIT & Ors. (2022) 328 CTR (Bom) 691 : (2022) 216 DTR (Bom) 386 and Mehul Jadavji Shah v. Dy. CIT (2018) 302 CTR (Bom) 344: (2018) 165 DTR (Bom) 366  Distinguished ,  UOI v. Manik Dattatreya Lotlikar (1988) 67 CTR (Bom) 37 and B. Muralidhar v. Dy. CIT (2020) 187 DTR (Mad) 162  (AY.2007-08)