Iron and steel hospital equipment treated as furniture under sales tax schedule on a broad reading

The expression "furniture made of iron and steel" in item 17 of the Kerala General Sales Tax Act was construed in its ordinary popular sense, read with the associated entries "safes" and "almirahs". The absence of any limiting word such as "household" meant the entry was not confined to domestic furniture. On that interpretation, hospital cots, lockers, screens, frames and similar iron-and-steel articles retained the character of furniture made of iron and steel, even though designed for hospital use, and were therefore taxable under item 17.

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Issues: Whether hospital equipments such as cots, lockers, screens, frames and similar articles made of iron and steel fall within item 17 of the First Schedule to the Kerala General Sales Tax Act, 1963 as furniture made of iron and steel.

Analysis: In fiscal statutes, words are ordinarily understood in their popular sense, but where no clear commercial or popular meaning is discernible the ordinary meaning in dictionaries may be used. The expression "furniture made of iron and steel" was not qualified by any restrictive word such as "household". Read in the context of the associated entries "safes" and "almirahs", the provision was held to cover iron and steel furniture generally and not merely domestic furniture. The hospital equipments, though specially designed for hospital use, retained the character of furniture made of iron and steel when understood in that wider sense.

Conclusion: The equipments were held to fall within item 17 and were taxable accordingly.

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