Inclusive definition of electronic goods covers cable connectors, preserving concessional tax treatment under the notification.

An inclusive fiscal notification covering electronic systems, instruments, appliances, apparatus, equipment, components, parts and materials was construed broadly, so connectors used to join cables were treated as electronic goods. Because the materials showed connectors were recognised as electronic components, a narrow exclusionary reading was rejected as unsustainable. The concessional four per cent rate therefore applied to the goods within the notification's scope.

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Issues: Whether connectors used to join cables fall within the expression "electronic goods" under G.O. Ms. No. 721, Revenue(s), dated 01.07.1985, so as to qualify for the reduced rate of tax at four per cent.

Analysis: The notification defined "electronic goods" in inclusive terms to cover electronic systems, instruments, appliances, apparatus, equipment operating on electronic principles, and all types of electronic components, parts and materials, besides enumerated categories. The materials placed before the Court showed that connectors were treated as electronic components in the relevant list issued by the Electronics Commission. In that setting, the exclusionary approach adopted in revision was held to be unsustainable, because the notification was not confined to the enumerated items alone and extended to components and parts as well.

Conclusion: Connectors were held to be electronic goods within the scope of the notification and the assessee was entitled to the concessional rate of tax.

Ratio Decidendi: Where a fiscal notification uses an inclusive definition covering components, parts and materials, goods specifically recognised as electronic components cannot be excluded by a narrow construction.

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