Transformer parts exemption: exclusion in a notification cannot be extended by implication to parts not expressly named.

The exemption notification excluded transformers and chokes for fluorescent tubes, but did not expressly exclude parts of transformers. Because exemption provisions must be construed according to their wording, the exclusion could not be extended by implication to cover transformer parts. Even if such parts were classifiable by reference to transformers on principal use, they retained their separate identity as parts. The parts of transformers were therefore outside the notification's exclusion, and the Revenue's challenge failed.

---

---

Issues: Whether the parts of transformers were excluded from the scope of Notification No. 160/86-CE, dated 1-3-1986, which denied exemption to transformers and chokes for fluorescent tubes.

Analysis: The exemption notification excluded transformers as such, but did not expressly exclude parts of transformers. Even if the parts were classifiable with reference to transformers because of principal use, they continued to retain their separate identity as parts. Since an exemption notification must be construed according to its wording, and the notification specifically mentioned parts where intended, the exclusion could not be extended by implication to transformer parts.

Conclusion: The parts of transformers were not covered by the exclusion in the notification, and the Revenue's challenge failed.

---