Trade parlance test for sales tax classification: dental chairs are equipment, not furniture, and fall under the residuary entry.

Classification of goods under a sales tax schedule is determined by trade parlance or common parlance. Applying that test, a dental chair was treated as commercially understood physiotherapy or treatment equipment, not as furniture, because its primary function is to facilitate dental treatment rather than serve as an ordinary article of convenience or decoration. Dental chairs were therefore held outside entry 56 of Schedule C and within the residuary entry 22 of Schedule E under the Bombay Sales Tax Act, 1959.

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Issues: Whether dental chairs manufactured and sold by the assessee were classifiable as furniture under entry 56 of Schedule C of the Bombay Sales Tax Act, 1959, or as goods falling under the residuary entry 22 of Schedule E.

Analysis: The classification of goods in sales tax schedules is to be determined according to the meaning attached to the goods in trade parlance or common parlance. On the evidence led before the Tribunal, including documentary material and a pamphlet describing the product, a dental chair was shown to be regarded commercially as physiotherapy equipment and not as furniture. The primary purpose of a dental chair is to facilitate dental treatment, not to serve as an ordinary article of convenience or decoration. In common-sense terms also, it is a specially designed piece of equipment rather than furniture.

Conclusion: Dental chairs do not fall within entry 56 of Schedule C as furniture and are covered by the residuary entry 22 of Schedule E. The question referred was answered in the affirmative in favour of the assessee.

Ratio Decidendi: In construing tariff or classification entries under a sales tax statute, the meaning of the commodity must be gathered from common or trade parlance, and an article specially designed as equipment for a particular function is not to be treated as furniture merely because it provides seating.

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