Liberal construction site exemption allows contractually allotted premises used solely for project work to qualify as the relevant site.

Exemption notifications for goods manufactured at the construction site were construed liberally, so the phrase "at site" was not confined to the exact physical location of the building work. A contractually allotted premises provided by the Government for safety, traffic, or practical reasons, and used exclusively for casting beams or similar items for the project, could form part of the relevant site. On that basis, the beams qualified for exemption, and the duty demand and penalty were unsustainable.

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Issues: Whether beams manufactured at a premises allotted by the Government away from the actual construction site, but exclusively used in the construction project, qualified for exemption under the notifications applicable to goods manufactured at the site of construction.

Analysis: The exemption notifications were intended to relieve goods manufactured for use in construction work at the project site from duty. The expression "at site" was held to require a liberal and purposive construction so that the benefit is not defeated by a narrow reading. Where the Government, for reasons of safety, traffic, and practicality, provides a separate premises under the contract for casting beams or similar goods, that premises forms part of the site for the purposes of the exemption if the goods are used solely in the construction work. The Board's circular also clarified that "site" is not to be read restrictively and includes any premises specifically made available under the contract for such construction activity.

Conclusion: The beams were eligible for exemption, the duty demand and penalty could not be sustained, and the appeal succeeded in favour of the assessee.

Ratio Decidendi: Exemption notifications for goods manufactured at the site of construction must be construed liberally, and a contractually allotted premises used exclusively for the project can constitute the relevant site for availing the exemption.

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