ORDER : Alok Aradhe, C.J. Mr. S.Dwarakanath, learned Senior Counsel representing Mr. Karthik Ramana Puttamreddy, learned counsel for the petitioners in W.P.Nos.6872, 7893, 22122, of 2012, 22144 of 2015 and 22789 of 2016. Mr. G.Vasantha Rayudu, learned counsel for the petitioner in W.P.No.31762 of 2012. Mr. Mohammed Imran Khan, learned Additional Advocate General for the respondents. 2. In this bunch of writ petitions, the core issue is with regard to the applicability of the Telangana Motor Vehicles Taxation Act, 1963 (hereinafter referred to as, “the Act”), in respect of the motor vehicle, which is registered in the name of the owner or occupier of the mine and is being worked personally by him for carrying out mining operations on such mine. Therefore, the writ petitions were heard analogously and being decided by this common order. 3. For the facility of reference, facts giving rise to filing of W.P.No.6872 of 2012 are being referred to. 4. The petitioner is a Government Undertaking engaged in the mining of coal. The Government of Andhra Pradesh holds share to the extent of 51%, whereas the Central Government holds share in the petitioner to the extent of 49%. The mines of the petitioner are spread over four districts, namely Karimnagar, Adilabad, Warangal and Khammam, in the State of Telangana. For the purposes of carrying out the mining activity, the petitioner has imported various earthmoving equipments like dumpers, cranes, dozers, drillers, motor graders, loaders etc. Some of the aforesaid equipments run on tyres while some of them are chain mounted. 5. A memo dated 11.11.2011 was issued by the Transport Commissioner to the Deputy Transport Commissioner, Adilabad and the Regional Transport Officer, Khammam to verify whether the equipments used by the petitioner in its mines are chain mounted or tyre mounted and also to verify whether they are capable of plying on the public roads or not so as to decide the issue whether the aforesaid equipments fall within the meaning of motor vehicles as defined in Section 2(28) of the Motor Vehicles Act, 1988, and the Rules thereunder. In pursuance of the aforesaid memo, the Motor Vehicle Inspector, Mancherial, inspected the equipment of the petitioner and submitted a report on 14.12.2011 to the transport authorities. However, a copy of the aforesaid report was not supplied to the petitioner. 6. In pursuance of the aforesaid memo, the Motor Vehicle Inspector, Mancherial, inspected the equipment of the petitioner and submitted a report on 14.12.2011 to the transport authorities. However, a copy of the aforesaid report was not supplied to the petitioner. 6. The Joint Commissioner of Transport (Planning & Administration), Hyderabad, vide memo dated 22.12.2011, directed the Deputy Transport Commissioner, Adilabad, and the Regional Transport Officer, Khammam, to collect the life tax on all tyre mounted vehicles operated by the petitioner and to report compliance. Thereupon, the Regional Transport Officer, Mancherial, issued a notice dated 27.12.2011 by which the petitioner was asked to furnish the details of the unladen weight of 29 vehicles working in Srirampur Division and 40 vehicles working in Bellampalli Division. 7. The petitioner submitted a reply to the aforesaid notice on 30.12.2011 and apprised the Regional Transport Officer that the writ petition challenging the levy of entry tax is pending before this Court. The petitioner requested the Regional Transport Officer not to take further action. Thereafter, the Regional Transport Officer issued 18 show cause notices dated 09.01.2012 to the petitioner in respect of 15 dumpers and 3 loaders proposing to levy tax and penalty under the Act. Thereafter, another notice dated 13.01.2012 was also issued to the petitioner. The petitioner submitted a reply to the aforesaid notice on 13.02.2012. Thereafter, this writ petition has been filed in which the petitioner has sought the relief that the vehicles used by the petitioner for the purposes of mining are exempt from payment of life tax under the provisions of the Act. The petitioner has also assailed the validity of the action of the respondents in demanding the life tax on the vehicles of the petitioner. Hence this writ petition. 8. Learned Senior Counsel for the petitioners, while inviting the attention of this Court to Section 10 of the Act, submitted that since the vehicles of the petitioners are registered in their name and are used by them in the mines, the provisions of the Act do not apply to the vehicles which are used by the petitioners in the mining area. It is submitted that the decision rendered by a Division Bench of the Andhra Pradesh High Court in Khader Basha v. Regional Transport Officer 2011 SCC OnLine AP 918 : (2013) 3 ALD 416 : (2012) 6 ALT 660 , is not applicable to the facts of the case and the decision of a Division Bench of this Court in M/s. Schlumberger Asia Service Limited v. Government of Andhra Pradesh (W.P.No.6383 of 2012, dated 20.03.2024), was dealing with the vehicles used in oil field services engaged in the onshore and offshore oil well electro logging services and therefore the said decision does not apply to the facts of the case. 9. On the other hand, learned Additional Advocate General has placed reliance on the Division Bench decision of the Andhra Pradesh High Court in Khader Basha (supra) as well as the Division Bench decision of this Court in M/s. Schlumberger Asia Service Limited (supra). 10. We have considered the rival submissions made on both sides and have perused the record. 11. The Andhra Pradesh Motor Vehicles Taxation Act, 1963, was enacted with an object to consolidate and amend the law relating to levy of a tax on motor vehicles in the erstwhile State of Andhra Pradesh. The aforesaid Act has been adopted by the State of Telangana on bifurcation of the State and is now known as the Telangana Motor Vehicles Taxation Act, 1963. Section 3 of the Act deals with levy of tax on motor vehicles. Explanation 4 to Section 3(2) of the Act provides for levy of life tax on the motor vehicles. Section 10 of the Act is extracted below for the facility of reference: “10. Provisions of this Act not to apply to the motor vehicles designed and used solely for agricultural and mining purposes:- (1) Nothing in this Act shall apply to a motor vehicle registered in the name of the owner or occupier of any agricultural land or mine if such land is under his personal cultivation or if such mine is being worked personally by him and such motor vehicle is designed and used solely for carrying out agricultural or mining operations on such land or mine or within a distance of fifteen miles from the limits of such land or mine. (2) Notwithstanding anything contained in the Act, a tax at rupees twenty-five per quarter shall be levied on any vehicle specified in sub-section (1), when the vehicle is not used solely for carrying out such agricultural or mining operations but is used by its registered owner for any other purpose of his own. Explanation I.- For the purpose of this section, the expression “agricultural operation” shall mean tilling, sowing, harvesting, crushing of agricultural produce or any other similar operation carried out for the purpose of agriculture; but shall not include the transporting of persons, manure or materials for the purpose of agriculture or the transporting of agricultural produce except when such transporting is made by the owner or occupier of the land for his own purposes :– (i) within a distance of fifteen miles from the limits of such land, or (ii) to or from the nearest market place irrespective of the distance of such market place from the limits of such land. Explanation II.- For the purpose of this section, “personal cultivation” means cultivation by a person of his own land and on his own account— (1) by his own labour; (2) by the labour of any member of his family; or (3) by servants on wages payable in cash or in kind or both or by hired labour under his personal supervision or under the personal supervision of any of his relatives. Explanation III.- For the purpose of this section, the expression “mining operation” means any operation undertaken for the purpose of winning any mineral.” 12. Thus, it is evident that Section 10 of the Act is a nonobstante clause and provides that if a motor vehicle registered in the name of the owner or occupier of any mine and if such mine is his being worked personally by him and such motor vehicle is designed and used solely for carrying out mining operations on such mine, the provisions of the Act do not apply. In view of the mandate contained in Section 10 of the Act, if the vehicles are registered in the name of the petitioners and they are being used exclusively for carrying out the mining operations, then the provisions of the Act would not apply in respect of such vehicles. 13. In view of the mandate contained in Section 10 of the Act, if the vehicles are registered in the name of the petitioners and they are being used exclusively for carrying out the mining operations, then the provisions of the Act would not apply in respect of such vehicles. 13. Reliance placed by the learned Additional Advocate General on the decision of this Court in M/s. Schlumberger Asia Service Limited (supra) is concerned, the same dealt with the vehicles used in onshore and offshore oil well electro logging services and did not deal with the vehicles used for the purposes of mining. 14. Therefore, the impugned show cause notices/impugned orders are quashed. However, the respondents are granted the liberty to ascertain whether the motor vehicles are exclusively being used by the petitioners for the purposes of mining operations. In case the vehicles used by the petitioners are solely for mining operations, then no action for levy of life tax shall be taken against such vehicles. In all other cases, the authorities shall be at liberty to proceed in accordance with law. It shall be open for the petitioners to make an application for refund of the amount, if any deposited by them in pursuance of the interim order, before the concerned authority. 15. Accordingly, the writ petitions are disposed of. Miscellaneous applications pending, if any, shall stand closed. However, there shall be no order as to costs.