Ruling authority at the instance of third party dealers. Therefore, the respondent cannot be given the advantage of reopening the assessment under the guise that the Advance Ruling authority has given a clarification, which will bind the goods dealt with by the petitioner. If the interpretation given by the respondent is to be accepted once again, this will run counter to the finality attached to an order of assessment as mentioned in Section 30(2) of the PVAT Act. One more submission made by the learned Government Advocate is that the authority while exercising the power under Section 77 of the PVAT Act does not enact a law or lays down a new principle, but clarifies what is in existence and such clarification could be applied retrospectively. Though, at the first blush, this argument appears to be impressive, but on a closer scrutiny, it is otherwise. If such interpretation is to accepted, then all assessments made prior to the date of clarification can very well be reopened by the assessing officer by computing the period of limitation from the date on which the authority issued clarification. This obviously cannot be done as Section 30(2) of the PVAT Act, clearly bars/prohibits re-assessment beyond a period of 5 years from the expiry of the year to which return under the Act relates. Therefore, there is no room for reckoning the date on which the clarification was issued by the Advance Ruling authority into Section 30(2),
