Strict construction of exemption notifications denies benefit for parts of photovoltaic systems not expressly covered.

An exemption notification must be applied strictly according to its terms, and a benefit for complete photovoltaic systems cannot be extended to parts unless expressly covered. The imported goods were found to be only parts of photovoltaic systems, while Notification No. 36/96 at Sl. No. 152(c) covered solar cells, modules and photovoltaic systems for the manufacture of photovoltaic applications. On that clear wording, the exemption did not apply to the imported items, and the Revenue's challenge succeeded. The impugned order was set aside and the appeal was allowed.

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Issues: Whether the imported goods, being only parts of photovoltaic systems, were entitled to the benefit of Notification No. 36/96 at Sl. No. 152(c), which covered solar cells and modules and photovoltaic systems for the manufacture of photovoltaic applications.

Analysis: The factual finding of the authorities below was that the goods imported were parts of photovoltaic systems. The notification, on its clear language, extended the exemption only to complete photovoltaic systems and not to parts thereof. On that basis, the benefit of the notification could not be enlarged to cover the imported items.

Conclusion: The exemption was not available to the imported goods and the Revenue's challenge succeeded.

Final Conclusion: The impugned order was set aside and the appeal was allowed.

Ratio Decidendi: An exemption notification must be applied according to its clear terms, and a benefit extended only to complete goods cannot be claimed for parts not expressly covered.

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