His argument is that as to motor vehicles the Commonwealth has occupied the entire taxing and licensing field and therefore Sec. 12 of the city charter gives no authority for imposing the tax since it limits the city's right to tax to subjects "as to which there is no restraint or prohibition by the Constitution or general law". He relies on Richmond-Petersburg Lines v. Richmond, 182 Va. 132, 28 S.E.2d 7, decided in 1943, particularly on the statements therein that the then Motor Vehicle Code and Motor Vehicle Carrier's Act were "intended to cover the whole subject of regulating the operation of automobiles upon all public highways of the State and the imposing of State and local licenses therefor"; that "general powers of taxation vested by charter in municipalities which are in conflict with these general statutes are thereby limited and modified"; and that, concededly, "unless the Motor Vehicle Code conferred the power upon the municipality to impose the local vehicle license tax upon the motor vehicles in question, there is no other authority to do so". 182 Va. at 134, 28 S.E.2d at 8. As pointed out in the opinion, the then Motor Vehicle Code, Acts 1932, ch. 342, p. 613, contained a provision that towns and cities might levy and assess taxes and charge license fees and taxes upon vehicles, as theretofore, with certain exceptions, but as amended by Acts 1936, p. 638, it provided t

1, supra, was added to the Code by chapter 666, Acts 1952, page 1113, which also added other sections to and amended certain sections of Title 46, the Motor Vehicle Code, the provisions of which must be read as a whole. Richmond-Petersburg Lines v. Richmond, 182 Va. 132, 28 S.E.2d 7. The Code Commission, as directed by Sections 9-70 and 9-75 of the Code, properly assigned the new section 46-416.1 to Article 3 (Revocation of Licenses), Chapter 6 (Motor Vehicle Safety Responsibility Act) of Title 46. Section 46-388 in chapter 6 declares it to be the legislative intent that this chapter shall be liberally construed so as to effectuate, so far as legally and practically possible, its primary objective "to promote and further greater safety in the operation of automotive vehicles in this State."

acts and also provided for the issuance of certificates of public convenience and necessity to such carriers, and the definition as there given but slightly altered now appears in section 56-273(d), Code of Virginia 1950. It thus appears that whenever a certificate of public convenience and necessity was to be issued for the operation of motor vehicles as common carriers thereunder a distinct meaning and significance was applied and attributed to the terms or descriptive words of "motor vehicle carrier" or "common carrier by motor vehicle." That a real and material difference and distinction existed between the character of transportation business in which motor vehicles were employed and operated as intrastate common carriers under the supervision and control of the Corporation Commission of Virginia, and the less regulated business of local moving and hauling of goods at will for compensation by any and all kinds of vehicles was recognized, and known to the City, cannot be doubted. Richmond-Petersburg Freight Lines v. Richmond, 182 Va. 132, 28 S.E.2d 7. Chapter 10 of the Richmond City Code of 1937, which is entitled "Concerning the Levy of Taxes and the Assessment of Licenses," was amended and reordained by the ordinance of December 23, 1947. It was by this ordinance that one who engaged in the business of "Packing, Crating, Shipping, Hauling or Moving Goods or Chattels for others" was first subjected to a license tax based upon the gross income derived from those specified businesses.