Common parlance test for furniture classification excludes specially designed hospital equipment from notification coverage.

Hospital articles other than operation tables were not treated as "furniture" under the notification because the term had to be understood in its ordinary and popular sense, not technically or artificially. The relevant test was whether the goods were commonly recognised as furniture in everyday usage, having regard to their function, and the mere fact that they could be used in a domestic setting was insufficient. As the catalogue described the disputed items as hospital equipment specially designed for hospital use, and the revenue failed to show that they were generally accepted as furniture, they were liable to tax as unclassified goods under the general charging provision.

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Issues: Whether the assessee's hospital articles, other than operation tables, were classifiable as "furniture" under the notification or were taxable as unclassified items under the general charging provision.

Analysis: The expression "furniture" in the notification was held to require construction according to its ordinary and popular meaning, not a technical or artificial one. The relevant inquiry was whether the articles are ordinarily understood and accepted as furniture in common usage, having regard to their function in daily living. The articles in question were described in the catalogue as hospital equipment and were specially designed for use in hospitals. Mere capacity to be used in a domestic setting was held insufficient; what mattered was whether they were generally recognised as furniture in the popular sense. On the record, the revenue had not established that the disputed articles answered that description.

Conclusion: The articles, other than operation tables, were not furniture within the meaning of the notification and were liable to be treated as articles chargeable under section 3 of the U.P. Sales Tax Act.

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