Strict reading of fiscal exclusions: transformer parts were not covered where the notification named transformers only.

A fiscal exemption or exclusion in Notification No. 160/86 must be read strictly according to its wording, and its scope cannot be expanded by implication. Because the notification excluded transformers but did not expressly exclude their parts, the exclusion was confined to transformers alone. The absence of any specific reference to parts showed no intention to deny concessional treatment to such goods, so parts of radiators remained entitled to the benefit of the notification.

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Issues: Whether the exclusion for transformers in Notification No. 160/86 dated 1-3-1986 extended to parts of transformers, or whether such parts remained eligible for the concessional benefit.

Analysis: The notification excluded transformers but did not expressly refer to parts thereof. By applying the reasoning that a concessional notification must be construed according to its wording, and by drawing support from the Tribunal's earlier view that where "parts" are not specifically included or excluded they are not to be read in by implication, the Court held that the exclusion could not be expanded beyond its plain terms. The absence of an express reference to parts showed that the Central Government did not intend to deny the benefit to parts of radiators.

Conclusion: The exclusion for transformers did not cover parts of radiators, and the goods were entitled to the benefit of Notification No. 160/86 dated 1-3-1986.

Ratio Decidendi: An exemption or exclusion clause in a fiscal notification must be confined to the goods expressly covered by its language, and where parts are not specifically excluded they cannot be denied the benefit by implication.

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