Strict construction of exemption notifications limits "generators" to generator simpliciter, excluding generating sets with prime movers.

An exemption notification referring to "generators" must be strictly construed, and the term was held not to extend to generating sets. Technical and trade materials, including CCCN/HSN references, treated a generator as a machine converting mechanical energy into electrical energy, while a generating set meant a generator combined with its prime mover on one unit or common base. Because the notification did not expressly cover such combined units, the benefit was confined to generator simpliciter and was unavailable for generating sets.

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Issues: Whether the goods manufactured and cleared by the assessee were "generators" entitled to the concessional rate under Notification No. 20/79, or "generating sets" outside the notification.

Analysis: The notification was construed strictly. The technical and trade materials, including the CCCN/HSN references, treated generators and generating sets as distinct articles. A generator was described as a machine converting mechanical energy into electrical energy, whereas a generating set consisted of a generator combined with its prime mover as one unit or on a common base. The materials also showed that generators could exist without prime movers, including hand or foot operation, and therefore the notification could not be extended to a combined set merely because the terms were used loosely in trade.

Conclusion: The assessee was not entitled to the benefit of the notification for generating sets; the benefit applied only to generator simpliciter.

Ratio Decidendi: An exemption notification referring to "generators" must be strictly construed and does not extend to generating sets consisting of a generator plus prime mover when the notification does not expressly cover such combined units.

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