Exemption notification interpretation allows factory-made goods used for maintenance to qualify despite no separate workshop.

Notification No. 281/86 exempted excisable goods manufactured in a workshop within the factory and used in the same factory for repair or maintenance. The expression "workshop" had previously been interpreted in the assessee's own case to cover the factory as a whole, rather than a separate tool room or confined area. On that construction, goods made within the factory and used for internal repair or maintenance qualified for the exemption even though they were not produced in a separate workshop in the strict sense. The exemption was therefore available to the assessee, and the denial of relief could not rest on a narrow reading of "workshop."

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Issues: Whether the benefit of Notification No. 281/86 dated 24-4-86 was available to goods manufactured in the factory and used within the factory for repair or maintenance of machinery, despite the goods not being made in a separate workshop.

Analysis: The notification exempted excisable goods manufactured in a workshop within the factory and intended for use in the same factory for repair or maintenance. The expression "workshop" had already been interpreted in the appellant's own case to mean the factory as a whole and not a confined tool room. Following that interpretation, goods manufactured within the factory and used for repair or maintenance inside the factory were covered by the exemption even if they were not produced in a separate workshop in the strict sense.

Conclusion: The exemption under Notification No. 281/86 dated 24-4-86 was available to the assessee.

Final Conclusion: The impugned order was set aside and the appeal was allowed with consequential relief.

Ratio Decidendi: An exemption notification using the expression "workshop" may be applied to the factory as a whole where prior binding interpretation has given that expression a wider meaning, and the exemption cannot be denied merely because the goods were not manufactured in a separate workshop in the strict sense.

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