Statutory clarification for assessment delays excludes time only when the Board actually resolves a referred question.

Section 14(6) of the Andhra Pradesh General Sales Tax Act allows exclusion of time only where the Board of Revenue issues a general or special direction that truly clarifies a question referred to it and that question has a direct bearing on assessment. A mere administrative instruction to keep dealer assessments pending, without answering any referred issue or removing ambiguity in law, does not qualify as a statutory clarification. Where the legal position had already been settled and the department only sought to defer assessments until legislative amendment, the period could not be excluded for limitation purposes and the assessment became time-barred.

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Issues: Whether the Board of Revenue's direction to keep assessments of dealers in jaggery pending was a clarification on a question referred to it within section 14(6) of the Andhra Pradesh General Sales Tax Act so as to exclude that period in computing the limitation for assessment.

Analysis: Section 14(6) permits exclusion of time only where the Board of Revenue, by general or special order, directs deferment of assessment pending clarification by it of a question referred to it, and the question must have a direct bearing on the assessment. The direction in question did not answer any referred question or remove any ambiguity in law. The legal position on jaggery assessments had already been settled by an earlier decision of the High Court, and what the department sought was merely a stoppage of assessments until the Legislature amended the provision. Such a direction was therefore administrative in character and not a statutory clarification within the meaning of the sub-section.

Conclusion: The Board's direction did not amount to a clarification under section 14(6), so the period covered by it could not be excluded for limitation purposes; the assessment was consequently time-barred.

Ratio Decidendi: Only a direction issued by the Board of Revenue that actually clarifies a referred question having direct bearing on assessment can extend the permissible assessment period under section 14(6); a mere administrative instruction to keep matters pending does not.

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