Hello,
Thank you for posting the question!
The deferment API limits start from the time that the device is made aware of the update requirement. In the case you outline below, the offline device will come online, realize there is an OS update, consult the application (if it has registered for deferment notifications), and allow the application to defer the update for up to 24 hours.
This API is designed for applications to ensure the device is in a "safe" state before update begins, which is why the period starts from the time the device is aware of it.
Hope this answer helps. Please let us know if you have any questions.