JUDGMENT judgment of court was delivered by Badar Durrez Ahmed J.-These six (6) writ petitions raise common issue and, therefore, same are being decided together. relevant assessment years are 2006-07 to 2011-12. By way of these writ petitions petitioner (Pepsico India Holdings P. Ltd.) has sought quashing of notices issued on August 2, 2013, under section 153C of Income-tax Act, 1961 (hereinafter referred to as "said Act"). search and seizure operation under section 132(1) of said Act was conducted on March 27, 2012, on Jaipuria group. It is case of Revenue that during said operation certain documents "belonging" to petitioner were found. Consequently, Assessing Officer of Jaipuria group prepared satisfaction note dated July 29, 2013, to effect that documents mentioned therein belonged to petitioner. It is, thereafter, that satisfaction note as well as said documents were symbolically handed over to Assessing Officer of petitioner. We use expression "symbolically handed over" because of fact that Assessing Officer of Jaipuria group and Assessing Officer of petitioner was one and same person. It is, thereafter, that said Assessing Officer issued notices to petitioner, all dated August 2, 2013, under section 153C of said Act seeking to reopen assessments of petitioner for years 2006-07 to 2011-12 and to follow procedure prescribed under section 153A of said Act. In response to said notices, petitioner submitted its objections on October 9, 2013. Those objections were rejected by order dated December 2, 2013, passed by Assessing Officer. Pursuant thereto, petitioner, being aggrieved by action taken and proposed to be taken against petitioner, has filed these writ petitions seeking quashing of said notices under section 153C of said Act. Before we examine these writ petitions in detail it would be pertinent to point out that recently in case of Pepsi Foods P. Ltd. v. Asst. CIT (W. P. (C.) No. 415 of 2014-since reported in [2014] 367 ITR 112 (Delhi), and other connected matters, this court had occasion to examine very provisions which are under consideration in matters before us. In judgment delivered on August 7, 2014, in case of Pepsi Foods Pvt. Ltd. (supra), after examining provisions of sections 153C, 132(4A)(i) and 292C(1)(i) of said Act, this court had observed as under (page 117): "On plain reading of section 153C, it is evident that Assessing Officer of searched person must be'satisfied' that, inter alia, any document seized or requisitioned'belongs to' person other than searched person. It is only then that Assessing Officer of searched person can handover such document to Assessing Officer having jurisdiction over such other person (other than searched person). Furthermore, it is only after such handing over that Assessing Officer of such other person can issue notice to that person and assess or reassess his income in accordance with provisions of section 153A. Therefore, before notice under section 153C can be issued two steps have to be taken. first step is that Assessing Officer of person who is searched must arrive at clear satisfaction that document seized from him does not belong to him but to some other person. second step is-after such satisfaction is arrived at-that document is handed over to Assessing Officer of person to whom said document'belongs'. In present cases it has been urged on behalf of petitioner that first step itself has not been fulfilled. For this purpose it would be necessary to examine provisions of presumptions as indicated above. Section 132(4A)(i) clearly stipulates that when, inter alia, any document is found in possession or control of any person in course of search it may be presumed that such document belongs to such person. It is similarly provided in section 292C(1)(i). In other words, whenever document is found from person who is being searched normal presumption is that said document belongs to that person. It is for Assessing Officer to rebut that presumption and come to conclusion or'satisfaction' that document in fact belongs to somebody else. There must be some cogent material available with Assessing Officer before he/she arrives at satisfaction that seized document does not belong to searched person but to somebody else. Surmise and conjecture cannot take place of'satisfaction'... 'It is evident from above satisfaction note that apart from saying that documents belonged to petitioner and that Assessing Officer is satisfied that it is fit case for issuance of notice under section 153C, there is nothing which would indicate as to how presumptions which are to be normally raised as indicated above, have been rebutted by Assessing Officer. Mere use or mention of word "satisfaction" or words "I am satisfied" in order or note would not meet requirement of concept of satisfaction as used in section 153C of said Act. satisfaction note itself must display reasons or basis for conclusion that Assessing Officer of searched person is satisfied that seized documents belong to person other than searched person. We are afraid, that going through contents of satisfaction note, we are unable to discern any "satisfaction" of kind required under section 153C of said Act'." While coming to aforesaid conclusions court had also examined decisions which had been cited on behalf of Revenue and which are, once again, being reiterated by learned counsel for Revenue before us. Those decisions are Kamleshbhai Dharamshibhai Patel v. CIT [2013] 214 Taxman 558 (Guj); CIT v. Classic Enterprises [2013] 358 ITR 465 (All) and decision of Division Bench of this court in SSP Aviation Ltd. v. Deputy CIT [2012] 346 ITR 177 (Delhi). This court had indicated in its judgment in Pepsi Foods Pvt. Ltd. (supra) that case of Kamleshbhai Dharamshibhai Patel (supra) was distinguishable on facts. Those observations would apply to present writ petitions also. As regards decision of Allahabad High Court in Classic Enterprises (supra), this court had indicated that it could not agree with conclusions and observations of Allahabad High Court inasmuch as decision of Allahabad High Court was premised on consideration of provisions of section 158BD of said Act which are entirely different from provisions of section 153C of said Act. Furthermore, with regard to decision in SSP Aviation Ltd. (supra), this court had noted that said decision does not militate against view taken in Pepsi Foods Pvt. Ltd. (supra). learned counsel for Revenue has cited additional decision before us today and that is case of Savesh Kumar Agarwal v. Union of India [2013] 353 ITR 26 (All). This decision also, in our view, does not advance case of Revenue. This would be evident from observations of Allahabad High Court in paragraphs 19 to 21 of said decision, which read as under (page 34 of 353 ITR): "In Manish Maheshwari's case [2007] 289 ITR 341 (SC) Supreme Court observed that taxing statute must be constructed strictly. court, however, shall not interpret statutory provisions in such manner, which would create additional physical burden on person. In case of any doubt or dispute, construction is to be made in favour of taxpayer and against Revenue. In present case, we do not find anything wrong in satisfaction note and forwarding of entire matter by Incometax Officer, Ward-III (2), Ahmedabad to Assessing Officer of petitioner at Bareilly. All requirements of section 153C were complied with by Income-tax Officer, Ward-III (2), Ahmedabad. search under section 132A was carried out and bullion was seized. case was selected for compulsory scrutiny for six assessment years. assessee established that seized silver belongs to M/s. Sarvesh Jewellers, Bareilly-the petitioner. ownership and consignment of petitioner was also confirmed by Assessing Officer of petitioner at Bareilly. Income-tax Officer, Ward-III (2), Ahmedabad did not commit any error in law, in recording satisfaction note requesting petitioner's Assessing Officer to proceed under section 153C of Income-tax Act. After assessment of person in respect of whom search action was carried out is completed, officer under section 153C, where he find that seized articles belong to some other person, has to forward satisfaction note to Assessing Officer on such person. satisfaction in such case is in respect of material and disclosures of person with which articles or assets are found and not in respect of person who whom they belong." (underlining added) above extract makes it clear that taxing statute must be construed strictly and in case of doubt or dispute construction in favour of assessee has to be adopted. Apart from this, material observations of Allahabad High Court in case of Savesh Kumar Agarwal (supra) is to be found in paragraph 20 thereof where it has been observed that assessee established that seized silver belongs to M/s. Sarvesh Jewellers, Bareilly-the petitioner. In other words, person from whom bullion was seized was able to establish that it did not belong to him but to Sarvesh Jewellers. It is in that context that provisions of section 153C of Act were invoked inasmuch as Assessing Officer would then be considered as having been satisfied that bullion which was seized from searched person did not belong to searched person but to some other person (in that case M/s. Sarvesh Jewellers, Bareilly). From foregoing discussion, it is evident that in order that Assessing Officer of searched person comes to satisfaction that documents or materials found during search belong to person other than searched person, it is necessary that he arrives at satisfaction that said documents or materials do not belong to searched person. We may point out that in course of arguments we had asked learned counsel for Revenue as to whether documents in question had been disclaimed by Jaipuria group. learned counsel for Revenue, on instructions, states that this was not case. In other words, it follows that Jaipuria group did not say that documents did not belong to them. It would now be necessary for us to examine satisfaction note dated July 29, 2013. said note is as under: "M/s. Pepsico India Holding Pvt. Ltd., Satisfaction Note Assessment year 2006-07 to 2011-12 July 29, 2013, Satisfaction note for issue of notice under section 153C of Income-tax Act, 1961, in case of M/s. Pepsico India Holding Pvt. Ltd. (PAN: AAACP1272G), for assessment years 2006-07 to 2011-12. In case of Jaipuria group, search and seizure action under section 132(1) of Income-tax Act, 1961, was carried out on March 27, 2012, and during course of search and seizure action certain documents/papers were found and seized. following documents which were found and seized during course of search and seizure action under section 132(1) of Income-tax Act, 1961, are found to be belonging to M/s. Pepsico India Holding Pvt. Ltd. (PAN: AAACP1272G) over which jurisdiction lies with undersigned: Party/Annx./Page Description of annexure No. These two pages are 10 years Cumulative Redeemable preference Shares of rupees 10 each, purchased by M/s. Pepsico India Holding Ltd. from B-2/A-11/34-35 M/s. Tripty Drinks Ltd. and 10 years Cumulative Redeemable Preference Shares of rupees 10 each, purchased by M/s. Pepsico India Holding Ltd. from M/s. SMV Beverages Ltd. This is cheque of Rs. 1,66,84002 in favour of B-2/A-14/60 Pepsico India Holding Pvt. Ltd. Issued by M/s. Neetar Beverages Pvt. Ltd. on June 30, 2012. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/61 Pepsico India Holding Pvt. Ltd. issued by M/s.Neetar Beverages Pvt. Ltd. on May 31, 2011. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/62 Pepsico India Holding Pvt. Ltd. issued by M/s. Neetar Beverages Pvt. Ltd. on May 31, 2010. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/63 Pepsico India Holding Pvt. Ltd. issued by M/s. Neetar Beverages Pvt. Ltd. on May 31, 2009. This is cheque of Rs. 5,46,91,818 in favour of B-2/A-14/64 Pepsico India Holding Pvt. Ltd. issued by M/s. SMV Agencies Pvt. Ltd. on June 30, 2012. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/65 Pepsico India Holding Pvt. Ltd. issued by M/s. SMV Agencies Pvt. Ltd. on May 31, 2012. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/66 Pepsico India Holding Pvt. Ltd. issued by M/s. SMV Agencies Pvt. Ltd. on April 30, 2012. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/67 Pepsico India Holding Pvt. Ltd. issued by M/s. SMV Agencies Pvt. Ltd. on June 30, 2011. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/68 Pepsico India Holding Pvt. Ltd. issued by M/s. SMV Agencies Pvt. Ltd. dated: April 30, 2011. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/69 Pepsico India Holding Pvt. Ltd. issued by M/s. SMV Agencies Pvt. Ltd. dated: June 30, 2010. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/70 Pepsico India Holding Pvt. Ltd. issued by M/s. SMV Agencies Pvt. Ltd. dated: April 30, 2010. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/71 Pepsico India Holding Pvt. Ltd. issued by M/s. SMV Agencies Pvt. Ltd. dated: April 30, 2009. This is cheque of Rs. 6,00,00,000 in favour of B-2/A-14/72 Pepsico India Holding Pvt. Ltd. issued by M/s SMV Agencies Pvt. Ltd. dated: June 30, 2009. These pages relates to supply and loan agreement C-2/A-1/101- made between Pearl Drinks Ltd. and Pepsico India 115 Holdings Pvt. Ltd. on October 1, 2010. I have examined abovementioned documents/paper and satisfied that provisions of section 153C of Income-tax Act, 1961, are applicable in case of M/s. Pepsico India Holding Pvt. Ltd. (PAN: AAACP1272G). As undersigned is having jurisdiction over case of M/s. Pepsico India Holding Pvt. Ltd. (PAN: AAACP1272G), notices under section 153C of Income-tax Act, 1961, are issued on July 29, 2013, for assessment years 2006-07 to 2011-12. (Pukini Lokho) Asstt. Commissioner of Income-tax, Central Circle-12, New Delhi" On going through satisfaction note it is evident that there are three kinds of documents which are mentioned therein. First, are photocopies of Cumulative Redeemable Preference Shares purchased by Pepsi Co India Holdings P. Ltd. from M/s. Tripty Drinks Ltd. and M/s. SMV Beverages Ltd. second set of documents are cheques found in cheque books of Jaipuria group companies. These cheques are unsigned and they are original leaves in cheque books themselves which belonged to Jaipuria group of companies. Though it must be pointed out that cheques had been written in favour of Pepsi Co India Holdings P. Ltd. third document is photocopy of supply and loan agreement made on October 1, 2010, between Pearl Drinks Ltd. and Pepsi Co India Holdings P. Ltd. In objections furnished by petitioner, it had specifically taken point that photocopies of preference shares do not belong to petitioner. photocopies belong to Jaipuria group. It was, however, stated that original preference shares certificates are with petitioner and it is originals which belong to them and not copies. It was also contended by petitioner in objections that unsigned cheques could, by no stretch of imagination, belong to petitioner as they had not even been handed over to petitioner and were to be found in cheque books of Jaipuria group companies themselves. In so far as copy of supply and loan agreement was concerned, petitioner pointed out that copy that was found in possession of Jaipuria group belonged to Jaipuria group whereas original which belonged to petitioner was with petitioner. Therefore, it was contended that none of documents found during course of searches conducted on Jaipuria group which find mention in satisfaction note dated July 29, 2013, could be said to have belonged to petitioner. Consequently, it was urged that proceedings under section 153C of said Act ought to be dropped. However, by virtue of order dated December 2, 2013, Assessing Officer rejected each one of these objections and observed that provisions of section 153C of said Act had been rightly invoked and petitioner was directed to comply with assessment proceedings under section 153C read with section 143(3) of said Act in so far as assessment years 2006-07 to 2011-12 were concerned. Having set out position in law in decision of this court in case of Pepsi Foods Pvt. Ltd. (supra), it must be seen as to whether Assessing Officer of searched person (the Jaipuria group) could be said to have arrived at satisfaction that documents mentioned above belonged to petitioners. First of all we may point out, once again, that it is nobody's case that Jaipuria group had disclaimed these documents as belonging to them. Unless and until it is established that documents do not belong to searched person, provisions of section 153C of said Act do not get attracted because very expression used in section 153C of said Act is that "where Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to person other than person referred to in section 153A..." In view of this phrase, it is necessary that before provisions of section 153C of said Act can be invoked, Assessing Officer of searched person must be satisfied that seized material (which includes documents) does not belong to person referred to in section 153A (i.e., searched person). In satisfaction note, which is subject matter of these writ petitions, there is nothing therein to indicate that seized documents do not belong to Jaipuria group. This is even apart from fact that, as we have noted above, there is no disclaimer on part of Jaipuria group in so far as these documents are concerned. Secondly, we may also observe that finding of photocopies in possession of searched person does not necessarily mean and imply that they "belong" to person who holds originals. Possession of documents and possession of photocopies of documents are two separate things. While Jaipuria group may be owner of photocopies of documents it is quite possible that originals may be owned by some other person. Unless it is established that documents in question, whether they be photocopies or originals, do not belong to searched person, question of invoking section 153C of said Act does not arise. Thirdly, we would also like to make it clear that Assessing Officers should not confuse expression "belongs to" with expressions "relates to" or "refers to". registered sale deed, for example, "belongs to" purchaser of property although it obviously "relates to" or "refers to" vendor. In this example if purchasers premises are searched and registered sale deed is seized, it cannot be said that it "belongs to" vendor just because his name is mentioned in document. In converse case if vendor's premises are searched and copy of sale deed is seized, it cannot be said that said copy "belongs to" purchaser just because it refers to him and he (the purchaser) holds original sale deed. In this light, it is obvious that none of three sets of documents copies of preference shares, unsigned leaves of cheque books and copy of supply and loan agreement-can be said to "belong to" petitioner. In view of foregoing discussion, we do not find that ingredients of section 153C of said Act have been satisfied in this case. Consequently, notices dated August 2, 2013, issued under section 153C of said Act are quashed. Accordingly all proceedings pursuant thereto stand quashed. writ petitions are allowed as above. There shall be no orders as to costs. All pending applications also stand disposed of. *** Pepsico India Holdings P. Ltd. v. Assistant Commissioner of Income-tax