https://www.taxtmi.com/caselaws?id=48787 The dominant issue was the interpretation of Notification No. 281/86-C.E. granting excise exemption to goods "manufactured in a workshop within a factory" for repair/maintenance. The tribunal held that "workshop" cannot be treated as co-terminus with "factory" under the Act's extended definition, as doing so would render the words "in a workshop" otiose and impermissibly expand the exemption. Applying ordinary meaning and strict construction of exemption notifications, it ruled the benefit is confined to goods separately produced in a distinct workshop within the factory and excludes commercial/mass production even if used for repair/maintenance. As the assessees neither pleaded nor proved manufacture in any such workshop, exemption was denied and the appeals were dismissed. en-us Thu, 06 Apr 2000 00:00:00 +0530 Sun, 04 Jan 2026 11:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=48787 The dominant issue was the interpretation of Notification No. 281/86-C.E. granting excise exemption to goods "manufactured in a workshop within a factory" for repair/maintenance. The tribunal held that "workshop" cannot be treated as co-terminus with "factory" under the Act's extended definition, as doing so would render the words "in a workshop" otiose and impermissibly expand the exemption. Applying ordinary meaning and strict construction of exemption notifications, it ruled the benefit is confined to goods separately produced in a distinct workshop within the factory and excludes commercial/mass production even if used for repair/maintenance. As the assessees neither pleaded nor proved manufacture in any such workshop, exemption was denied and the appeals were dismissed. Case-Laws Central Excise Thu, 06 Apr 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=48787