Movable storage rack systems as goods and steel furniture where factory-made units remain usable after installation.

A manufactured sliding storage system assembled in the factory and installed on rails at the customer's premises was treated as goods, not immovable property, because it did not become a permanent structure by erection at site and remained capable of use as racks. It was also regarded as steel furniture under Tariff Item No. 40, since its essential function was storage and it operated as movable steel racks. Authorities on cinema chairs, storage bins, power-operated racks, and fixed storage cabins were distinguished on the basis that the present article was a manually movable storage system.

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Issues: (i) whether the sliding storage system was goods or immovable property; and (ii) whether it was correctly classifiable as steel furniture under Tariff Item No. 40 of the Central Excise Tariff.

Issue (i): whether the sliding storage system was goods or immovable property.

Analysis: The system was manufactured as a complete unit in the factory and then taken to the customer's premises for fitting on rails. Although the rails were embedded at site and the racks could move on them, the article did not come into existence by erection at site in the nature of a permanent structure. The racks remained capable of use as racks and the fact that they were mounted on rails did not convert the manufactured article into immovable property.

Conclusion: The product was goods and not immovable property.

Issue (ii): whether it was correctly classifiable as steel furniture under Tariff Item No. 40 of the Central Excise Tariff.

Analysis: The system consisted of steel racks intended for storage, and its essential function was that of office/storage furniture. The cited authorities relating to cinema chairs, storage bins, and power-operated racks were distinguished on their facts because the present article was a manually movable set of steel racks performing only a storage function. Shelving racks had also been treated as steel furniture in prior authority, and the departmental clarification relied on concerned fixed storage cabins rather than movable racks.

Conclusion: The product was correctly classifiable under Tariff Item No. 40 as steel furniture.

Final Conclusion: The appeal failed because the sliding storage system was treated as movable manufactured goods and was held to fall within the tariff entry for steel furniture.

Ratio Decidendi: A manufactured storage rack system that is complete when removed from the factory, remains movable in use, and functions as storage furniture is classifiable as steel furniture rather than immovable property.

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