Tribunal held that that the PCIT while giving approval had simply mentioned “satisfied”. Similarly the Additional Commissioner had simply mentioned “yes”, it was a fit case to issue notice under S. 148 of the Income-tax Act, 1961. Since both the approving authorities had given the approval in a mechanical manner, the reassessment proceedings were not in accordance with law. On merits the Appellate Tribunal held that even if the Department’s theory of the assessee having enabled the clients to claim contrived losses, the Department had to bring on record some evidence of the income earned by the assessee in the process, be it in the nature of commission or otherwise. The AO had added the entire amount of doubtful transactions by way of the assessee’s additional income, which was wholly impermissible.( AY.2009-10)