Excise

Concession/Exemption/Incentive/Rebate

— Exemption — Notification exempting all goods manufactured in a mine from duties and additional duties of excise — Moreover, the notification assigning to the word <169>mine<170> the same meaning as assigned in S. 2(1)(j), Mines Act, 1952 — Entitlement to exemption thereunder — Workshop established to facilitate repair of mining machinery and equipment used in adjacent coal mines and declared by Central Government as a mine under S. 82, Mines Act, 1952 — Such a workshop if was a workshop in the precincts of a mine and entitled to exemption under the said notification — Answered in the affirmative — Applying purposive rule of interpretation, broader and not narrower meaning given to the word <169>precincts<170> — Since the said word has several meaning, held, literal rule of interpretation could not be applied to it — Further held, the question of entitlement to exemption was covered by Central Excise Act and had no relevance with the Factories Act — CEGAT erred in denying the benefit of exemption to the said workshop merely because the mine was registered under the Factories Act, S. 2(m) whereof excluded from the definition of <169>factory<170> a mine subject to the operation of Mines Act, 1952, (2006) 6 SCC 340