Broad reading of "work relating to roads" extends exemption to highway safety barrier installation and road safety works.

Work involving installation of profile-safety steel barriers at a hazardous location on a national highway was treated as work relating to roads for exemption purposes. The expression "relating to" was given a broad meaning, and safety measures at toll plazas were regarded as integral to modern road construction and road safety. On that basis, the exemption certificate and notification were read as covering the activity, so the remaining objections did not require separate consideration. The challenge based on Rule 14 also failed because no fraud or misrepresentation was shown, and the factual findings below consistently favoured the assessee.

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Issues: Whether fixing of profile-safety steel barrier at a hazardous location on National Highway No. 8 was a work contract relating to roads so as to qualify for the exemption granted.

Analysis: The exemption certificate and the notification were read as covering work relating to roads, and the expression "relating to" was given a broad meaning. Safety measures installed on a national highway, including profile-safety steel barriers at toll plazas, were treated as integral to modern road construction and road safety. Once the work was found to be part of the road, the remaining questions did not survive for separate consideration. The plea based on Rule 14 was rejected because no fraud or misrepresentation was established and the authorities below had recorded a consistent factual finding in favour of the assessee.

Conclusion: The work was held to relate to roads and the exemption was upheld in favour of the assessee.

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