Strict construction of exemption notifications barred extending relief to petrol pump parts not expressly covered.

Exemption notifications are construed strictly, and relief cannot be extended by implication to goods not expressly covered. In this commentary on petrol pump parts classified under Heading 84.13, the notification referred to pumps but did not mention parts, so the benefit was held unavailable despite reliance on tariff description and a plea for harmonious construction. The plain wording of Notification No. 155/86 controlled the result, and interpretative reasoning could not substitute for an express reference to parts.

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Issues: Whether parts of petrol pumps classified under Heading 84.13 were entitled to exemption under Notification No. 155/86.

Analysis: The exemption notification was construed strictly. The tariff entry referred to pumps, but the notification did not use the word parts. In the absence of an express reference to parts, the benefit could not be extended by interpretation merely because the tariff heading and the goods description were said to be identical. The requested application of harmonious construction was rejected in view of the plain language of the notification.

Conclusion: The parts of petrol pumps were not eligible for exemption under Notification No. 155/86.

Ratio Decidendi: An exemption notification must be construed strictly, and where the notification does not expressly cover parts, exemption cannot be extended to parts by interpretative reasoning.

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