Dismissing the petition the Court held that Second proviso to S. 149(1) states  that in cases where notice under S 153A or S. 153C is required to be issued in relation to a search conducted under S. 132 or books of account and other documents or any asset are requisitioned under S.  132A on or before 31st March, 2021, the time frame prescribed by S.  149(1) is inapplicable.  In cases of search  there is no restriction of time period for issuance of notice under S. 148. Accordingly the ground raised by assessee by relying upon second proviso to S. 149(1) is held to be not tenable.