Pragmatic meaning of "site of construction" supports exemption for precast drain boxes made in a nearby casting yard.

Goods manufactured in a casting yard about half a kilometre from the flyover worksite were treated as manufactured at the site of construction for use at that site. The expression "site" was given a pragmatic construction, because the work made it impractical to manufacture the components at the exact spot of construction. As the casting yard formed part of the construction arrangement and the drain boxes were used solely in the flyover project, the exemption under notification 59/90 was held to be available.

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Issues: Whether precast water drain boxes manufactured at a casting yard about half a kilometre away from the flyover site were entitled to the exemption for goods manufactured at the site of construction for use at that site under notification 59/90.

Analysis: The exemption covered goods manufactured at the site of construction of buildings for use at site. The expression "site" was not to be given a unduly restrictive meaning where the work itself made it practically impossible to manufacture the components at the exact spot of construction. The casting yard was part of the construction arrangement and the goods were solely used in the flyover project. A pragmatic view was ated to hold that goods made at a nearby allotted site, though not on the exact line of the highway work, satisfied the requirement of manufacture at the site of construction.

Conclusion: The drain boxes were manufactured at the site of construction for use at that site, and the exemption was available to the assessee.

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