Court held that when an assessment or reassessment is set aside or cancelled, pursuant to an order under section 263 , the consequent fresh assessment can only be made, before the expiry of two years from the end of the financial year in which the order under section 263 was and not after that. When such assessment or reassessment or recomputation is made for the purpose of giving effect to any finding or direction in the order under section 263 , it can be completed, at any time. However though no limitation is prescribed the order should be passed within reasonable time , delay of eight and half years is held to be not valid in law . The order should be passed within reasonable time . (WP No . 2664 of 2013 dt 27-03 2019 ) (AY.1990 -91)