Exemption for auxiliary plant electricity upheld where grid power was only used for start-up and generation followed from station output.

Notification No. 51/78 was interpreted as extending exemption to electricity generated by a station and supplied to its auxiliary plants for generation purposes. Electricity from the main grid was used only to start the auxiliary stations; once they began operating, the main supply was switched off and power generated by those stations was used for the relevant purpose. That factual position was supported by the Chief Engineer's clarification and was not displaced by any contrary technical material from the Revenue. The notification benefit was therefore correctly applied.

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Issues: Whether the benefit of Notification No. 51/78 dated 01-03-1978 was available to electricity used for starting auxiliary plants and for electricity produced by the auxiliary stations for generation purposes.

Analysis: The exemption under the notification applied where electricity was produced by generating stations and supplied to the auxiliary plants of such stations for generation purposes. The record showed that electricity from the main grid was used only to start the auxiliary stations, after which the main supply was switched off and electricity generated by the auxiliary stations was used for the relevant purposes. This factual position was supported by the Chief Engineer's clarification and was not rebutted by any expert opinion or technical material from the Revenue.

Conclusion: The benefit of the notification was correctly extended, and the Revenue's challenge failed.

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