Common-parlance meaning of furniture controlled classification, and factory-used articles remained furniture under the First Schedule.

Tables, stools, trays, racks and similar articles sold to a match factory were treated as furniture under entry 121 of the First Schedule because the term "furniture" was construed in common parlance to include furniture used in homes, offices, factories and other places. Special design for factory use did not alter their character, and mere use in a factory did not make them factory equipment unless the statute expressly excluded them. The articles therefore fell within entry 121 and were not taxable at the general multipoint rate under section 3(1); the assessment classification made by the Appellate Assistant Commissioner was restored and the Tribunal's contrary view was set aside.

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Issues: Whether tables, stools, trays, racks and similar articles sold to a match factory fell within entry 121 of the First Schedule as furniture, or were taxable at the general multipoint rate under section 3(1).

Analysis: Entry 121 covered "furniture of all kinds not specifically mentioned" and was wide enough to include furniture used in homes, offices, factories and similar places. The expression "furniture" was understood in common parlance and included specially designed furniture as well. Mere use of the articles in a factory did not change their character as furniture, and they could not be treated as factory equipment merely because they were designed for a particular use.

Conclusion: The articles sold to the match factory fell within entry 121 of the First Schedule and were not taxable at the multipoint rate under section 3(1); the revision was allowed in favour of the Revenue.

Final Conclusion: The assessment classification made by the Appellate Assistant Commissioner was restored, and the Tribunal's contrary view was set aside.

Ratio Decidendi: Goods remain "furniture" if they answer that description in common parlance, even when specially designed for use in a factory, unless the statute expressly excludes them.

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