Tax classification of home UPS depends on statutory entry and technical evidence, not brochure claims or added conditions.

A taxing entry cannot be narrowed by adding conditions not found in the notification or statute. For home UPS products, classification under the notified information technology entry must turn on the text of the entry and the product's nature, not on brochure claims, assumed user restrictions, or alleged technical features such as exclusive computer use or inbuilt battery requirements. Promotional material is not determinative, while technical evidence and test reports remain relevant and must be considered. The impugned classification order was therefore set aside and the matter remanded for reconsideration of whether the UPS is capable of use with information technology products and, if so, classification under the concessional entry.

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Issues: Whether home UPS marketed for domestic use is classifiable under S.No. 68 of Part B of the First Schedule to the TNVAT Act as an information technology product notified by the Government, or under the residuary entry; and whether the assessing authority could read conditions into the notification based on use, brochure contents, or alleged technical features.

Analysis: The entry under S.No. 68, read with the notification issued on 01.01.2007, refers to "Uninterrupted Power Supply" without attaching conditions as to exclusive use with computers, inbuilt battery, pure sine wave output, or any other limiting criteria. In a fiscal statute, the Court cannot add words or supply conditions that the legislature or notification does not contain. Classification must therefore follow the language of the entry and the nature of the product, not an expanded user-based test introduced by administrative clarification. The brochure or advertisement of the product is not determinative of classification, since promotional material cannot override the statutory description. The Court also held that expert material and test reports are relevant in classification disputes and cannot be discarded perfunctorily. On the facts, the impugned order was found to have ignored these settled principles and to have rejected relevant material without proper consideration.

Conclusion: The rejection of classification under S.No. 68 was unsustainable. The matter was remanded to the assessing authority to determine whether the UPS sold by the petitioner is capable of being used with information technology products, and if so, to classify it under S.No. 68 and levy tax accordingly.

Final Conclusion: The writ petitions succeeded only to the extent of setting aside the impugned classification order and directing reconsideration on the limited question of eligibility for the concessional entry, with consequential assessment to follow the remand outcome.

Ratio Decidendi: A taxing entry cannot be curtailed by reading in conditions not found in the text, and classification must be made on the statutory description and relevant technical evidence rather than on advertising, assumed user restrictions, or administrative add-ons.

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