Dismissing the appeal of the Revenue the Court held  that the Principal Commissioner had failed to satisfactorily record his concurrence. Mere penning down the expression “yes” could not be considered to be valid approval. Though the Assistant Commissioner had appended his signature by writing in his hand “Yes, I am satisfied”, the Principal Commissioner had merely written “Yes” without specifically noting his approval, while recording the satisfaction for issuance of notice under section 148 for reopening the assessment under section 147. Therefore, the order of the Tribunal holding that the Assessing Officer had initiated the reassessment proceedings on the basis of borrowed satisfaction and that the prescribed authority had granted approval under section 151 in a mechanical manner need not be interfered with. (AY.2009-10)