CEMINDIA CO. LTD. vs BACHUBHAI N. RAVAL

The Supreme Court held that under Section 1(3)(b) of the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952, an establishment engaged exclusively in the building and construction industry is not subject to the Act for its workshop activities if those activities are ancillary and not for third-party benefit. The Court found that the appellant's workshop, used solely for maintaining its own equipment, did not constitute a separate industry, thus allowing the appeal against the Regional Provident Fund Commissioner's demand for contributions. The judgment clarified the definition of 'building and construction industry' to include all activities necessary for its effective operation.