Water supply project exemption extended beyond the first storage point where pipes formed part of the treatment system.

The exemption under Notification No. 6/2002-C.E., as amended, covered pipes required for delivery of water from the source to the plant and onward to storage facilities; it was not limited to the first storage point. A later departmental clarification could not add a restriction not found in the notification, and because the work formed part of the water treatment project with the required certificates obtained, the exemption was available.

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Issues: Whether the exemption under Notification No. 6/2002-C.E. as amended by Notification No. 47/2002-C.E. was confined only to pipes and equipment used up to the first storage point in a water supply project, or whether it extended to pipes used for delivery of water to subsequent storage facilities forming part of the water treatment system.

Analysis: The exemption notification, as amended, covered pipes required for delivery of water from the source to the plant and from there to the storage facilities. The wording did not impose a limitation that the exemption would cease at the first storage point. The later departmental clarification could not be read as supplying such a restriction into the unamended notification. Since the work executed formed part of the water treatment project and the relevant certificates had been obtained, the benefit of exemption was available.

Conclusion: The exemption was not restricted to the first storage point, and the assessee was entitled to the benefit of the notification.

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