Narrow construction of exemption exclusions preserves benefit for transformer parts where notification did not expressly exclude them.

An exemption notification excluding transformers and chokes for fluorescent tubes did not extend, on its plain wording, to parts of transformers. Radiators found to be transformer parts therefore remained within the notification benefit, and the departmental appeal failed. The principle applied was that an exclusion in an exemption notification must be read narrowly and cannot be extended to component parts without clear words.

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Issues: Whether radiators forming part of transformers were excluded from the benefit of Notification No. 160/86 dated 1-3-1986, which excluded transformers and chokes for fluorescent tubes from its purview.

Analysis: The exclusion in the notification was confined to transformers and chokes for fluorescent tubes. It did not extend to parts of transformers. Since the radiators were found to be parts of the transformer, they continued to fall within the benefit of the notification.

Conclusion: The radiators were entitled to the benefit of Notification No. 160/86 and the department's appeal failed.

Ratio Decidendi: An exclusion in an exemption notification must be construed according to its plain scope and does not, without clear words, extend to parts of the goods specifically excluded.

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