Purposive interpretation of water supply exemption extends to casing pipes used to carry untreated water to treatment plants.

Pipes used as casing pipes for tube wells were held eligible for exemption where the competent authority certified that they were intended to carry water from the source to the treatment plant for human and animal consumption. The notification was construed purposively, so as not to defeat its object of extending relief to water treatment plants. A narrow reading confined only to pipes physically conveying water would frustrate that purpose, and the Board's clarification supported exemption for pipes required to obtain untreated water from the source to the plant. The pipes were therefore covered by the exemption and the Revenue's challenge failed.

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Issues: Whether pipes used as casing pipes for tube wells, but certified for use in a water supply scheme, were eligible for exemption under the notification covering pipes needed for delivery of water from its source to the plant and to the storage facility.

Analysis: The exemption notification had to be construed so as not to defeat its object of extending relief to water treatment plants. The certificate issued by the competent authority stated that the pipes were intended for carrying water from the source to the treatment plant for human and animal consumption. The clarification issued by the Board also supported exemption for pipes required for obtaining untreated water from its source to the plant. A narrow construction limiting relief only to pipes physically carrying water would frustrate the purpose of the notification.

Conclusion: The pipes were covered by the exemption and the Revenue's challenge failed.

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