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Issues: Whether the trolley type stands manufactured as an accessory to room air-coolers fell within the meaning of steel furniture under Entry 40 of the First Schedule to the Central Excises and Salt Act, 1944.
Analysis: The expression "furniture" was not defined in the Act and had to be understood in its ordinary and popular sense. On that approach, furniture denotes equipment or movable articles with which a house or business premises is furnished for use or convenience. The trolley stand, though supplied with the air-cooler as an accessory, was held to be an item that furnished the room for better utility of the air-cooler and was not shown to be a necessary component for the working of the cooler itself. The authorities relied on by the petitioner were distinguished because the disputed articles there were integral parts of vehicles or hospital equipment and not independently describable as furniture.
Conclusion: The trolley type stand was held to be steel furniture within Entry 40 and therefore liable to excise duty. The petition was dismissed.