Purposive interpretation of single registration rules prevents denial for factory premises separated only by a vacant plot.

A beneficial fiscal instruction on single registration was construed purposively to advance its object, and connected factory premises forming part of the same manufacturing unit were held not to lose eligibility merely because they were separated by a vacant plot rather than a public road, railway line or canal. Where common raw material, labour, administration, and tax treatment existed, the restrictive reading could not override the notification's purpose, and no prejudice to revenue was shown. Single registration was therefore directed to be granted.

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Issues: Whether single registration could be denied to two premises of the same factory merely because they were separated by an intervening vacant plot and not by a public road, railway line or canal.

Analysis: The application for single registration had been rejected by relying on Notification No. 36/01-C.E. (N.T.) dated 26-6-2001 and the CBEC Excise Manual, on the premise that separation by a public road, railway line or canal was a necessary condition. The premises belonged to the same manufacturer and the other conditions of common raw material, common labour, common administration and common sales tax and income tax treatment were satisfied. The restrictive reading of the instruction was held not to control the object of the notification. The provision governing single registration was construed purposively so as to advance the legislative intent, since the premises formed part of the same factory and no prejudice was caused to the revenue.

Conclusion: Single registration could not be refused on the ground that the premises were separated only by a vacant plot. The rejection order was set aside and registration was directed to be granted.

Ratio Decidendi: A beneficial fiscal instruction governing single registration must be construed purposively, and separation of connected factory premises by a vacant plot will not by itself defeat eligibility where the premises otherwise form part of the same manufacturing unit.

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