Relays held distinct from switches, so exemption notification excluding switches did not bar relief.

Relays were treated as distinct commercial commodities from switches, even though both perform the function of making or breaking electrical circuits. Technical dictionaries, HSN Explanatory Notes and ISI specifications were used to distinguish the two items, and the earlier view that relays are not switches was followed. On that basis, relays were held to fall within Notification No. 160/86 dated 01.03.1986, because the exclusion applied only to switches. The Revenue's challenge therefore failed, and the exemption benefit remained available to relays.

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Issues: Whether relays manufactured by the assessee were entitled to the benefit of Notification No. 160/86 dated 01.03.1986, or whether they were to be treated as switches excluded from the notification.

Analysis: The distinction between relays and switches was examined with reference to technical dictionaries, HSN Explanatory Notes and ISI specifications. Although both items perform the function of making or breaking electrical circuits, they are not the same commodity. The earlier decision holding relays to be distinct from switches and eligible for the same exemption notification was followed.

Conclusion: The benefit of the exemption notification was held to be available to relays, and the Revenue's challenge failed.

Ratio Decidendi: Where relays and switches are recognized as distinct commercial commodities, the mere similarity in functional use does not justify denying an exemption notification that excludes switches only.

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