Mining machinery means specialised mechanical equipment, so miner's safety cap lamps do not qualify for section 80-I relief.

Section 80-I relief depends on profits being attributable to a priority industry, including manufacture of articles or things listed in the Sixth Schedule. Mining machinery in item No. (4) of that Schedule is read as a specialised mechanical contrivance under the statutory classification in the Industries (Development and Regulation) Act, 1951, and not every article or tool used in mining. On that construction, miner's safety cap lamps are articles used in mining but are not themselves machinery. The lamps therefore do not fall within item No. (4) of the Sixth Schedule and do not qualify the assessee for deduction under section 80-I on that basis.

---

---

Issues: Whether miner's safety cap lamps could be treated as mining machinery within item No. (4) of the Sixth Schedule to the Income-tax Act, 1961, so as to qualify for relief under section 80-I.

Analysis: Section 80-I grants deduction only where the profits are attributable to a priority industry, and priority industry includes manufacture of articles or things specified in the Sixth Schedule. Item No. (4) of that Schedule incorporates mining machinery as a specialised item under heading 8 of the First Schedule to the Industries (Development and Regulation) Act, 1951. Reading the provision with the statutory classification, mining machinery denotes mechanical contrivances of a specialised character and not every article or tool used in mining. Applying the accepted meaning of machinery, miner's safety lamps are articles used in mining but do not themselves constitute machinery.

Conclusion: The lamps were not mining machinery within item No. (4) of the Sixth Schedule, and the assessee was not entitled to relief under section 80-I on that basis; the answer was against the assessee and in favour of the Revenue.

---