Ultratech Cement Limited vs The State Of Gujarat

The Supreme Court considered whether heavy earth moving machinery and special service vehicles such as dumpers, loaders, excavators, surface miners, dozers, drills, and rock breakers fall within the definition of 'motor vehicles' under Section 2(28) of the Motor Vehicles Act, 1988, and are thus liable to pay tax under the Gujarat Motor Vehicles Tax Act, 1958. The Court analyzed the statutory language and legislative intent behind the classification of motor vehicles. It held that such machinery used primarily for construction and mining purposes do not qualify as motor vehicles under the Act and are not subject to motor vehicle tax. Consequently, the appeals were allowed in favor of the appellant, Ultratech Cement Ltd.