Allowing the appeal of the Revenue the Court held that the assessee had substantiated the value based upon the chartered accountant’s certificate and other documents which according to the assessee were placed before the Assessing Officer and also before the Tribunal. It was evidently clear that no satisfaction was recorded by the Assessing Officer in the assessment order dated March 28, 2016. Curiously enough after the Assessing Officer affixed his signature and seal, a note had been mentioned in the assessment order and the note was not for the assessee. Even assuming the note could be referred to by the assessee, the note did not record any satisfaction as required under section 56(2)(viib). The Tribunal committed a serious error in reversing the order passed by the Principal Commissioner. The order of revision setting aside the assessment order was justified. Income-Tax authority should record satisfaction for either accepting or not accepting explanation. Satisfaction of an administrative or a quasi-authority should be manifest and vivid on the face of the order or proceedings. There can be no inference as regards satisfaction, nor can the provision of law be read in to connote deemed satisfaction.(AY.2013-14)