Ordinary meaning of furniture: gun-rest trestles were held classifiable and taxable as furniture.

Where the taxing statute and notification did not define "furniture," the term was construed in its ordinary commercial sense. A movable iron stand used for resting and storing guns in armouries, gunsmiths' shops and some homes was held to be an article of convenience or furnishing for a place of use. The article did not cease to be furniture merely because it was not meant for domestic comfort or decoration. On that construction, trestles used for resting guns were classifiable as furniture and taxable as such.

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Issues: Whether trestles used for resting guns are classifiable as furniture and taxable as furniture under the relevant sales tax entry.

Analysis: The expression "furniture" was not defined in the taxing statute or the notification, so its meaning had to be gathered from the ordinary sense in which the word is understood. The article in question was a movable iron stand used for resting and storing guns in armouries, gunsmiths' shops, and sometimes homes. An article does not cease to be furniture merely because it is not used for domestic comfort or decoration; the proper test is whether, in ordinary parlance, it is regarded as an article of convenience or furnishing for a place of use. On that approach, trestles answer the description of furniture.

Conclusion: Trestles are articles of furniture and are liable to be taxed as such. The question was answered in the affirmative in favour of the department and against the assessee.

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