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Issues: Whether the rotary disc screen equipment, along with its electrical equipment, used in underground copper mining fell within item 72(18) ICT as mining machinery.
Analysis: The tariff did not define mining machinery. The Court treated the meaning of mining operation as encompassing the full chain of activities involved in extracting and handling ore from prospecting through underground work to bringing the ore to the surface. It accepted the expert evidence that underground screening was a necessary part of the mining process in the facts of the case, since the ore had to be reduced and segregated before economical lifting. The equipment was therefore not to be viewed as merely indirectly connected or as an optional auxiliary machine, but as part of the total mining machinery used for efficient and optimum utilisation of the mining system. The Court also held that the electrical equipment could not be separated from the principal machinery for the purpose of classification.
Conclusion: The rotary disc screen equipment and the connected electrical equipment were mining machinery under item 72(18) ICT, and the contrary revisional order could not stand.
Ratio Decidendi: Where a tariff entry for mining machinery is undefined, machinery that forms an integral and necessary part of the mining process, including underground screening required for economical extraction and lifting of ore, is classifiable as mining machinery.