Strict construction of exemption notifications excludes motor running capacitors treated as power capacitors from customs relief.

Motor running capacitors were treated as a variety of power capacitors under the relevant technical and Indian Standard usage, so functional differences, size, dimensions, or supplier descriptions did not take them outside that class. Because Notification No. 188/87-Cus. excluded power capacitors, the exemption had to be construed strictly and could not be extended beyond its plain scope. On that basis, motor running capacitors were not eligible for the exemption and fell outside the notification. The stated principle is that goods matching the ordinary technical meaning of an excluded class cannot be brought within an exemption by relying on descriptive or functional distinctions.

---

---

Issues: Whether motor running capacitors imported by the respondents were covered by Notification No. 188/87-Cus. or were excluded as power capacitors.

Analysis: The relevant Indian Standard and electro-technical vocabulary treated motor running capacitors as a variety of power capacitor. The distinction based on size, dimensions, purpose, or supplier catalogues was held insufficient to take them outside the expression "power capacitors". As the exemption notification excluded power capacitors, it had to be construed strictly and could not be extended beyond its plain scope.

Conclusion: Motor running capacitors were held to be power capacitors and therefore not entitled to the benefit of Notification No. 188/87-Cus., in favour of Revenue.

Ratio Decidendi: Where an exemption notification excludes a class of goods, the goods falling within the ordinary and standard technical definition of that class cannot be brought within the exemption by relying on functional distinctions or descriptive differences.

---