UPS cannot be treated as an inverter for taxation where prior notifications and commercial understanding treat it as a separate product.

An administrative clarification treating UPS as an inverter for higher taxation was found unsustainable because it conflicted with an earlier notification and prior clarification that treated UPS as a separate product. The court also accepted that UPS and inverter are distinct in commercial understanding and functionality, and that the taxing entry did not fit the product description. Although the challenge had become largely academic due to the absence of reopening and replacement of the enactment, the clarification was still examined on merits and was quashed as unsupported by material, in favour of the assessee.

---

---

Issues: Whether the impugned clarification classifying UPS as an inverter and taxing it accordingly was legally sustainable.

Analysis: The clarification was found inconsistent with the earlier governmental notification and prior clarification, both of which treated UPS as a separate product. The Court also noted that UPS and inverter are distinct products in commercial understanding and functionality, and that the entry relied on for higher taxation did not fit the product description. Although the challenge had become largely academic because no reopening had been initiated and the enactment had since been replaced, the Court still examined the validity of the clarification and found it unsupported by material.

Conclusion: The clarification was held to be unsustainable and was quashed, in favour of the assessee.

---