https://www.taxtmi.com/caselaws?id=92036 Exemption notifications must be construed strictly, and an exclusion applies only where the text expressly covers the goods in question. Because Notification No. 160/86 referred to transformers under Heading 85.04 but did not expressly exclude parts of transformers, those parts were not treated as excluded from exemption. The fact that other entries in the same notification specifically excluded parts where intended supported that interpretation, and Note 2(b) to Section XVI did not by itself extend the exclusion to transformer parts. Denial of exemption on that basis was therefore unsustainable. en-us Mon, 08 Jun 1998 00:00:00 +0530 Mon, 24 Oct 2011 11:41:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=92036 Exemption notifications must be construed strictly, and an exclusion applies only where the text expressly covers the goods in question. Because Notification No. 160/86 referred to transformers under Heading 85.04 but did not expressly exclude parts of transformers, those parts were not treated as excluded from exemption. The fact that other entries in the same notification specifically excluded parts where intended supported that interpretation, and Note 2(b) to Section XVI did not by itself extend the exclusion to transformer parts. Denial of exemption on that basis was therefore unsustainable. Case-Laws Central Excise Mon, 08 Jun 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=92036