Is 'Yes, I am satisfied' enough for the sanctioning authority to write?
No. Recorded that way, the satisfaction is mechanical and shows no sign that the officer's reasons were examined. The s.148 notices were held unsustainable and the department's SLP was dismissed.
Decided by the Supreme Court (A.K. Sikri J and Rohinton Fali Nariman J (SC); Rajendra Menon J and Sanjay Yadav J (MP High Court)) on 2015-07-08, reported as [2015] 64 taxmann.com 313 (SC); (2016) 237 Taxman 378 (SC); (2023) 453 ITR 242 (SC); below, CIT, Jabalpur v. S. Goyanka Lime & Chemicals Ltd. [2015] 56 taxmann.com 390 / (2015) 231 Taxman 73 (MP). It bears on section 147, section 148, section 151 of the Income Tax Act 1961, in Reassessment & Reopening matters.
This is the sentence that most sanction proformas actually contain, so it is the most directly usable of the sanction authorities. It is also worth knowing that the Supreme Court's part in it is a dismissal, not a reasoned judgment.
Binding on every court and authority in India.
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A search was conducted at the assessee's residential and business premises on 12 December 2002, and a notice for block assessment under s.158BC followed for the block period 1 April 1998 to 12 December 2002. Returns filed for each assessment year were processed under s.143(1). Notices under s.148 were then issued on 31 December 2004 on recorded reasons, the assessee's objections were rejected, and assessments were completed under s.143(3) read with s.147. The Commissioner (Appeals) found that the sanctioning Joint Commissioner had recorded no more than that he was satisfied, and quashed the notices; the Tribunal upheld that, and the Revenue's six appeals came to the High Court.
The Revenue's appeals were dismissed by the High Court. Recording sanction as 'Yes, I am satisfied' was mechanical, showed no application of mind, and made the assumption of jurisdiction to reopen invalid; the High Court held that no question of law arose from the concurrent orders of the Commissioner (Appeals) and the Tribunal. The Supreme Court order that follows is two lines - delay condoned, special leave petition dismissed - so it neither affirms the reasoning nor lays down any law of its own.
The High Court found that the Joint Commissioner, while according sanction, had recorded only 'Yes, I am satisfied'. Applying Arjun Singh v. Asstt. DIT [2000] 246 ITR 363 (MP), a coordinate Bench decision holding that such a formula shows the officer signing on the dotted line rather than applying his mind and that satisfaction must be objective and rest on objective material, the Court held the mechanical recording of satisfaction to be clearly unsustainable and found no error in the interference by the two appellate authorities. The Explanation to s.151 inserted by the Finance Act 2008 was held to pertain only to the issuance of the notice and not to the manner of recording satisfaction, so it did not assist the Revenue. Given the concurrent findings below and Arjun Singh, the Court held that no question of law arose and dismissed the appeals.
Delay condoned. The special leave petition is dismissed.
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Handle my notice → Ask a CA on WhatsAppNo. Recorded that way, the satisfaction is mechanical and shows no sign that the officer's reasons were examined. The s.148 notices were held unsustainable and the department's SLP was dismissed. This was decided by the Supreme Court (A.K. Sikri J and Rohinton Fali Nariman J (SC); Rajendra Menon J and Sanjay Yadav J (MP High Court)) and bears on section 147, section 148, section 151 of the Income Tax Act 1961. It is reported as [2015] 64 taxmann.com 313 (SC); (2016) 237 Taxman 378 (SC); (2023) 453 ITR 242 (SC); below, CIT, Jabalpur v. S. Goyanka Lime & Chemicals Ltd. [2015] 56 taxmann.com 390 / (2015) 231 Taxman 73 (MP). This is the sentence that most sanction proformas actually contain, so it is the most directly usable of the sanction authorities. It is also worth knowing that the Supreme Court's part in it is a dismissal, not a reasoned judgment. If it applies to you, the first step is this: Obtain the sanction and quote the authority's exact words in your objection.
A search was conducted at the assessee's residential and business premises on 12 December 2002, and a notice for block assessment under s.158BC followed for the block period 1 April 1998 to 12 December 2002. Returns filed for each assessment year were processed under s.143(1). Notices under s.148 were then issued on 31 December 2004 on recorded reasons, the assessee's objections were rejected, and assessments were completed under s.143(3) read with s.147. The Commissioner (Appeals) found that the sanctioning Joint Commissioner had recorded no more than that he was satisfied, and quashed the notices; the Tribunal upheld that, and the Revenue's six appeals came to the High Court. The matter was decided on 2015-07-08 by the Supreme Court (A.K. Sikri J and Rohinton Fali Nariman J (SC); Rajendra Menon J and Sanjay Yadav J (MP High Court)). On those facts the Supreme Court held as follows. The Revenue's appeals were dismissed by the High Court. Recording sanction as 'Yes, I am satisfied' was mechanical, showed no application of mind, and made the assumption of jurisdiction to reopen invalid; the High Court held that no question of law arose from the concurrent orders of the Commissioner (Appeals) and the Tribunal. The Supreme Court order that follows is two lines - delay condoned, special leave petition dismissed - so it neither affirms the reasoning nor lays down any law of its own.
The High Court found that the Joint Commissioner, while according sanction, had recorded only 'Yes, I am satisfied'. Applying Arjun Singh v. Asstt. DIT [2000] 246 ITR 363 (MP), a coordinate Bench decision holding that such a formula shows the officer signing on the dotted line rather than applying his mind and that satisfaction must be objective and rest on objective material, the Court held the mechanical recording of satisfaction to be clearly unsustainable and found no error in the interference by the two appellate authorities. The Explanation to s.151 inserted by the Finance Act 2008 was held to pertain only to the issuance of the notice and not to the manner of recording satisfaction, so it did not assist the Revenue. Given the concurrent findings below and Arjun Singh, the Court held that no question of law arose and dismissed the appeals. In the words reproduced by the source cited on this page: "Delay condoned. The special leave petition is dismissed."
It was decided by the Supreme Court on 2015-07-08 and is reported as [2015] 64 taxmann.com 313 (SC); (2016) 237 Taxman 378 (SC); (2023) 453 ITR 242 (SC); below, CIT, Jabalpur v. S. Goyanka Lime & Chemicals Ltd. [2015] 56 taxmann.com 390 / (2015) 231 Taxman 73 (MP). Binding on every court and authority in India. A Supreme Court decision binds every assessing officer, every Commissioner (Appeals), every bench of the Income Tax Appellate Tribunal and every High Court in India. An officer who declines to follow it is acting contrary to law, and that refusal is itself a ground of appeal. On section 147, section 148, section 151, the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It helps the taxpayer. The Revenue's appeals were dismissed by the High Court. Recording sanction as 'Yes, I am satisfied' was mechanical, showed no application of mind, and made the assumption of jurisdiction to reopen invalid; the High Court held that no question of law arose from the concurrent orders of the Commissioner (Appeals) and the Tribunal. The Supreme Court order that follows is two lines - delay condoned, special leave petition dismissed - so it neither affirms the reasoning nor lays down any law of its own. It arises in Reassessment & Reopening matters, on section 147, section 148, section 151 of the Income Tax Act 1961, and was decided by A.K. Sikri J and Rohinton Fali Nariman J (SC); Rajendra Menon J and Sanjay Yadav J (MP High Court). Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. Point out that nothing in the approval shows the reasons were read — that absence is the defect. Check who granted it as well as how, because the correct limb of s.151 is a separate ground.
Still good law. The rule stated by the Madhya Pradesh High Court continues to be applied - the Delhi High Court in PCIT-7 v. Pioneer Town Planners (P.) Ltd. [2024] 160 taxmann.com 652 (Delhi), 20 February 2024, is among the decisions turning on it. What is not good law is any suggestion that the Supreme Court settled the point: it dismissed the special leave petition in two lines, without reasons, so the authority is the High Court's and binds as such. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
The Supreme Court's order runs to two sentences - delay condoned, special leave petition dismissed - and is not a speaking judgment. Dismissal of a special leave petition without reasons decides nothing beyond that case and is not an affirmance, so cite this for the proposition only through the Madhya Pradesh High Court judgment below, which is where the reasoning is. The Supreme Court order is Petition for Special Leave to Appeal (C) CC No. 11916 of 2015, decided by A.K. Sikri and Rohinton Fali Nariman JJ on 8 July 2015; the High Court judgment is in IT Appeal Nos. 82 to 84 and 87 to 89 of 2012, decided by Rajendra Menon and Sanjay Yadav JJ. The date of that High Court judgment is given as 14 October 2014 in the text of the judgment itself but as 15 October 2014 both in the Supreme Court's record of the special leave petition and in the High Court's own listing; the two have not been reconciled. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
The Revenue's appeals were dismissed by the High Court. Recording sanction as 'Yes, I am satisfied' was mechanical, showed no application of mind, and made the assumption of jurisdiction to reopen invalid; the High Court held that no question of law arose from the concurrent orders of the Commissioner (Appeals) and the Tribunal. The Supreme Court order that follows is two lines - delay condoned, special leave petition dismissed - so it neither affirms the reasoning nor lays down any law of its own.
TaxSphere, “CIT v S. Goyanka Lime & Chemical Ltd”, https://taxnotice.vittsphere.com/caselaw/case/cit-v-s-goyanka-lime/ (validity last checked 2026-08-19)
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