Strict construction of exemption notifications denied relief where switches were expressly excluded from coverage.

Exemption notifications are construed strictly on their plain language, and their scope cannot be enlarged by earlier tariff classifications or trade notices where the wording is clear. Because Notification No. 160/86 expressly excluded switches, plugs and sockets, no distinction could be drawn based on whether the goods were used close to the main apparatus or at a distance. The benefit of the notification was therefore not available to the switches cleared by the assessee, and exemption was denied.

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Issues: Whether the benefit of Notification No. 160/86 dated 1-3-1986 was available to switches cleared by the assessee.

Analysis: Exemption notifications are to be construed strictly on the plain language used in them. The notification specifically excluded switches, plugs and sockets from its coverage and did not create any distinction based on whether such goods were used proximate to the main apparatus or at a distance. The earlier tariff classification and trade notices could not be used to expand or alter the scope of an exemption notification when its wording was clear.

Conclusion: The benefit of the notification was not available to the goods in question and the assessee was not entitled to exemption.

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