Solar energy exemption for traffic signals and street lights upheld under non-conventional energy notifications.

Solar power traffic signal systems and solar street lights were treated as covered by the exemption notifications for non-conventional energy devices/systems. The interpretation accepted that solar energy is a form of non-conventional energy and that the prescribed list included solar-based applications, so goods operating on electricity converted from solar energy fell within the expression "other applications." A narrow grammatical reading was rejected, and ejusdem generis was applied to preserve the scope and purpose of the notifications. The denial of exemption was therefore unsustainable.

---

---

Issues: Whether solar power traffic signal systems and solar street lights were covered by the exemption notifications for non-conventional energy devices/systems.

Analysis: The goods were examined with reference to the relevant exemption entries, which covered non-conventional energy devices/systems specified in the prescribed list. The reasoning accepted that solar energy is a form of non-conventional energy and that the list included several solar-based applications. The impugned goods operated on electricity converted from solar energy and were treated as falling within the expression "other applications" in the list. The interpretation adopted rejected a narrow grammatical approach and applied the principle of ejusdem generis to give effect to the scope and spirit of the notifications.

Conclusion: The goods were held eligible for the exemption notifications, and the denial of benefit was unsustainable.

---