The reassessment proceedings arose pursuant to the decision of the Supreme Court in Union of India v. Ashish Agarwal. The Tribunal held that while computing limitation under section 149, the period required to be excluded under the third proviso to section 149(1), as explained by the Supreme Court in Union of India v. Rajeev Bansal, had to be considered. On the facts, the reassessment order was passed beyond the period of limitation and was therefore liable to be quashed. (AY. 2013-14).