Solar energy exemption for traffic signals and street lights upheld under a broad reading of the notification entry.

Solar power traffic signal systems and solar street lights were treated as non-conventional energy devices covered by Notification No. 6/2002-C.E. because the exemption entry for solar energy applications was read broadly in light of List 9. The goods operated through electricity converted from solar energy, and that functional link was held sufficient to bring them within the notified class. A narrow grammatical construction was rejected as inconsistent with the purpose of encouraging non-conventional energy use, and ejusdem generis was applied to align the goods with the listed solar applications. Exemption was therefore available, with consequential relief following.

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Issues: Whether solar power traffic signal systems and solar street lights were entitled to exemption under Notification No. 6/2002-C.E. dated 01.03.2002 as non-conventional energy devices/systems falling within the relevant entry for solar energy applications.

Analysis: The relevant notification entry covered non-conventional energy devices/systems specified in List 9, and the list referred to several solar-energy-based applications, including solar photovoltaic modules for pumping water and other applications. The goods in question operated by electricity converted from solar energy, and their function was held to fall within the broad expression used in the notification. A restrictive grammatical reading was rejected because it would defeat the purpose of the exemption, which was to encourage non-conventional energy use. The interpretive approach accepted the application of ejusdem generis to treat the impugned goods as covered by the class of solar energy applications contemplated by the notification.

Conclusion: The exemption was available to the solar power traffic signal systems and solar street lights, and the appeals were allowed with consequential relief.

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