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Issues: Whether a jeep carrying excisable goods could be treated as "goods" and seized under Section 110 of the Customs Act as made applicable to proceedings under the Central Excises and Salt Act, and whether the separate provision for confiscation of conveyances under Section 115 excluded vehicles from the scope of the seizure power.
Analysis: By virtue of Section 12 of the Central Excises and Salt Act, certain provisions of the Customs Act were applied to excise matters, including Section 110. The definition of "goods" in the Customs Act included vehicles, and the scheme of Sections 111, 113 and 115 did not justify reading the separate confiscation provision for conveyances as excluding vehicles from the general meaning of "goods" in the seizure provision. The separate treatment of conveyances in Section 115 served a distinct purpose, since that provision covered situations where confiscation was directed at the conveyance as such and not merely as goods. The proviso to Section 115(2) likewise did not mean that vehicles were not confiscable.
Conclusion: The jeep was liable to be seized under Section 110, and the contrary view of the Single Judge was incorrect.