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20.2 Similarly, in the case of CIT vs. RRJ Securities Ltd. (supra), Hon'ble Jurisdictional High Court has observed as under:

"It was contended on behalf of the revenue that the hard disk contained data pertaining to the assessee and, therefore, it was rightly held that the hard disc belong to the assessee. Concededly, this contention would not be sustainable in view of the principles laid down with regard to the interpretation of the words 'belongs to' in section 153C of the Act. The hard disk was recovered from the computer belonging to 'B' which contained soft copies of working papers and balance sheet pertaining to the assessee for its income tax filing. It has been contended that 'B' is a Chartered Accountant and had the data pertaining to the assessee in his professional capacity. Merely because such data pertained to the assessee who claims to be a client of 'B' the hard disk could not be stated to belong to the assessee. It is not disputed that the said hard disk also did not contain any incriminating material as the data on the hard disc only supported the return filed by the assessee. This apart, as the hard disc did not belong to the assessee, proceedings under section 153C could not be initiated on the basis of the said disk."