Dismissing the appeal  of the revenue the Court held that the search and the issuance of notice under section 153C pertained to the period prior to June 1, 2015 and section 153C as it stood at the relevant time applied. The change brought about prospectively with effect from June 1, 2015 by the amended section 153C(1) did not apply. Therefore, the onus was on the Department to show that the incriminating material or documents recovered at the time of search belonged to the assessee. It was not enough for the Department to show that the documents either pertained to the assessee or contained information that related to the assessee. The Department had relied on three documents to justify the assumption of jurisdiction under section 153C against the assessee. Two of them, viz., the licence issued to the assessee by the Director, Town and Country Planning and the letter issued by him permitting the assessee to transfer such licence, had no relevance for the purposes of determining escapement of income of the assessee for the assessment year 2005-06. Consequently, even if those two documents could be said to have belonged to the assessee they were not documents on the basis of which jurisdiction could be assumed by the Assessing Officer under section 153C . The third document, the statement made by the searched party during the search and survey proceedings, was not a document that “belonged” to the assessee. While it contained information that “related” to the assessee, it could not be said to be a document that “belonged” to the assessee. Therefore, the jurisdictional requirement of section 153C as it stood at the relevant time, was not met. No question of law arose. ( AY. 2005 -06)