Tariff classification of mining equipment turns on ordinary meaning: road-adapted vehicles remain conveyances, not mining machinery.

Tariff classification of imported dumpers, loaders, wheel loaders, taxvactors and crawler tractors depended on the ordinary and statutory meaning of the competing entries. Item 75 was treated as a conveyance entry, while Item 72(18) covered mining machinery. The stated principle was that vehicles adapted for use on roads remain conveyances even if used in mining areas or fitted for loading and unloading. The material produced did not establish a trade meaning that would bring the goods within mining machinery, and the other items were likewise not shown to fall within that entry. The classification under the conveyance entry was therefore upheld.

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Issues: Whether imported dumpers, loaders, wheel loaders, taxvactors and crawler tractors were classifiable as mining machinery under Item No. 72(18) of the First Schedule to the Customs Tariff Act or as conveyances under Item No. 75.

Analysis: The classification turned on the statutory language of the competing tariff entries and the nature of the goods. The tariff scheme treated Item No. 75 as a transport-material entry, while Item No. 72(18) covered mining machinery. The Court relied on prior authorities holding that dumpers, though used in mining areas and equipped for loading and unloading, remain vehicles or conveyances if they are adapted for use on roads. The fresh material produced did not displace the earlier view, and the evidence did not establish that the goods had acquired a trade meaning as mining machinery. The Court further held that items such as wheel loaders, taxvactors and crawler tractors were not shown to fall within the mining machinery entry.

Conclusion: The goods were not classifiable as mining machinery and were correctly assessed under the conveyance entry.

Final Conclusion: The appeals failed, and the classification adopted by the lower authorities was upheld.

Ratio Decidendi: Where tariff entries compete, classification must follow the ordinary and statutory meaning of the goods in the relevant entry; vehicles adapted for transport remain conveyances and are not treated as mining machinery merely because they are used in mining operations or fitted with loading and unloading features.

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