NEW DELHI, Jan. 8 -- In a major relief to companies operating heavy industrial and construction equipment, the Supreme Court on Wednesday ruled that specialized off-road machinery used within factory premises, mines and industrial areas cannot automatically be treated as motor vehicles liable to road tax, even if such equipment is capable of limited movement.

A bench comprising justices Pankaj Mithal and Prasanna B. Varale delivered the ruling on a plea filed by UltraTech Cement Ltd, which had challenged a 2011 Gujarat High Court order allowing the levy of motor vehicle tax on construction equipment.

By setting aside the high court's ruling, the apex court brought to an end a long-running dispute affecting sectors such as cement, mining...