Plain-language reading of exemption notifications bars denying benefit by implying a parts-versus-sub-parts distinction.

Stampings and laminations used in electric motors, rotors and stators, which were in turn used as component parts in the manufacture of power driven pumps, were treated as eligible for exemption under Notification No. 64/86 as amended. The denial of exemption was based only on the argument that the goods were parts of parts rather than parts of the pumps themselves. The notification was read in its plain terms, and no distinction between parts and sub-parts was implied into it. In taxing exemptions, benefit cannot be refused by importing a limitation not expressed in the notification.

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Issues: Whether stampings and laminations used in electric motors or rotors and stators, which in turn are used as component parts in the manufacture of power driven pumps, qualified for exemption under Notification No. 64/86 as amended.

Analysis: The items were found to be used in the electric motors or in rotors and stators, and those in turn were used as component parts in the manufacture of power driven pumps. The denial of exemption rested only on the view that the goods were parts of parts of power driven pumps and not parts of the pumps themselves. The notification did not draw any distinction between parts and sub-parts, and there was no warrant to read such a limitation into its plain language. In a taxing exemption, benefit cannot be denied by importing a supposed intention contrary to the words used in the notification.

Conclusion: The goods were eligible for exemption under Notification No. 64/86 as amended, and the denial of exemption was not justified.

Final Conclusion: The appeals succeeded and the benefit of exemption was extended to the goods in question.

Ratio Decidendi: Where the language of an exemption notification covers the goods in plain terms, the benefit cannot be denied by implying a distinction between parts and sub-parts that the notification does not express.

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