Tax classification of iron and steel components: separately sold slotted angles and panels were not furniture before the amendment.

Separately sold slotted angles and iron or steel panels were not treated as "furniture" under entry 145 of the Kerala General Sales Tax Act before the 1984 amendment, because in common commercial parlance they were only component parts and not furniture usable as such. The later amendment, which expressly included furniture or parts thereof, confirmed that the pre-amendment entry did not extend to such components. They were therefore assessable only under the residuary entry for iron and steel articles, and the turnover could not be taxed under the furniture entry for the relevant assessment year.

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Issues: Whether slotted angles and panels made of iron or steel, sold separately, fell within entry 145 of the First Schedule to the Kerala General Sales Tax Act, 1963 as "furniture" before its amendment by the Kerala Finance Act, 1984.

Analysis: Entry 145, as it then stood, covered safes, almirahs and furniture made of iron or steel. The goods in question were separately sold components and were not, in common parlance or in the commercial world, understood as furniture usable as such. The fact that they could later be assembled or manipulated into racks or ladders did not make the component parts themselves furniture. The amended entry, which expressly referred to furniture or parts thereof, showed that the pre-amendment entry did not extend to separately sold components. The earlier decisions cited were distinguishable because they dealt with items that were themselves used and usable as furniture.

Conclusion: Slotted angles and panels sold separately did not fall under entry 145 before the amendment and were assessable only under the residuary entry for iron and steel articles.

Final Conclusion: The turnover of the goods could not be taxed under the furniture entry for the relevant assessment year, and the assessment was directed to be modified accordingly.

Ratio Decidendi: A tax entry covering furniture made of iron or steel does not include separately sold component parts that are not themselves known or usable as furniture in common commercial parlance, unless the entry expressly so provides.

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