Dismissing the petition the Court held  that the entire scheme of reopening of assessment under section 147, in search cases had undergone a change by paradigm shift of the reassessment proceedings replacing the earlier block assessment and thereafter the provisions under section 153A read with section 153C for reopening of the past assessment years on the basis of material found during the course of search were applicable. According to the amendment Dismissing the petition the Court held that  the satisfaction note could not be said to be a communication as contemplated under Board Circular No. 19 of 2019 ((2019) 416 ITR (St.) 140) and even otherwise it could be regularized by issuing a copy of the satisfaction note with a document identification number which would be a procedural aspect for issuing notice under section 148 which already contained the document identification number and date. That there was no time limit prescribed for initiation of reassessment proceedings and sending the proposal for reopening the assessment under section 147 on the basis of search and seizure under section 132. The time limit provided in Board Circular No. 24 of 2015 ((2016) 380 ITR (St.) 32) was prescribed for recording satisfaction of the Assessing Officer of the searched person either at the time of initiation of proceedings against the searched person or during the course of assessment proceedings or immediately after assessment proceedings were completed. Such guidelines would not apply for recording satisfaction note in the case of a person other than the searched person on the basis of materials seized or found during the course of search. Writ petition dismissed. (AY. 2017-18)