Strict construction of exemption notifications denied partial exemption for washing machines outside the notified scope.

Notification No. 54/93 was construed strictly as an exemption provision, so the burden was on the assessee to show that its product clearly fell within the notified scope. The notification covered only parts of household washing machines, including machines that both wash and dry, and not every washing machine product by description alone. On a plain reading, the appellants' washing machine did not fall within the four corners of the notification, so partial exemption was not available and the denial of benefit was upheld.

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Issues: Whether the appellants were entitled to partial exemption under Notification No. 54/93 dated 28-2-1993 in respect of washing machines manufactured by them.

Analysis: The notification was read according to its plain language, which covered only parts of household washing machines, including machines that both wash and dry. As an exemption notification, it was required to be construed strictly, and the burden lay on the appellants to show that their product clearly fell within its scope. The washing machine manufactured by the appellants did not fall within the four corners of the notification.

Conclusion: The appellants were not entitled to the partial exemption under Notification No. 54/93, and the denial of benefit was upheld.

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