Court Upholds Assessment Validity u/s 147; Clarifies Distinction Between "Belongs to" and "Relates to" in Tax Documents.

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....Validity of assessment u/s 147 instead of u/s 153C - AO should not confuse the expression ‘belongs to’ with the expression ‘relates to’ or ‘refers to’. - the documents in the case in hand belonged to the searched person. Under such circumstances the reopening in the case in hand has rightly been done under section 147 of the Act by the AO. - AT....