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Issues: Whether a vehicle used for transporting excisable goods, found to be carrying dutiable goods without payment of duty, could be seized and detained under Section 110 of the Customs Act, 1962 as applied by notification under Section 12 of the Central Excises and Salt Act, 1944.
Analysis: Section 12 authorised application of specified Customs Act provisions to excise duty matters, and the notification brought Section 110 of the Customs Act, 1962 into the excise regime with necessary modifications. Section 110 permits seizure of goods liable to confiscation, and the Court held that the word "goods" should receive its ordinary grammatical meaning. The absence of a separate definition of "goods" in the Central Excises and Salt Act, 1944 did not justify restricting the term so as to exclude a vehicle. Section 115 of the Customs Act, 1962 also supported confiscation where vehicles were used in connection with dutiable goods liable to confiscation. Rule 200 of the Central Excise Rules, 1944 was treated as a search provision and not as limiting the statutory power of seizure under Section 110.
Conclusion: The vehicle was legally seizable and the challenge to its detention failed.