Excise classification turns on ordinary meaning and actual use, not nomenclature, for steel furniture entries.

For excise classification, the ordinary commercial meaning and actual use of the goods govern whether an item falls within a tariff entry for steel furniture. Articles made of steel are not treated as furniture merely because of their shape, nomenclature or inclusion in departmental lists if their true character is industrial equipment rather than household or office furniture. On that approach, trolleys, storage bins, pump stands and similar factory-use articles are outside Tariff Item No. 40 and cannot be subjected to duty and licensing as steel furniture. The analysis rejects reliance on names alone and requires classification by common parlance and functional character.

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Issues: Whether the seven manufactured items, namely the trolleys, storage bins, stainless steel pump stands and box with door, were classifiable as "steel furniture" under Tariff Item No. 40 and therefore liable to excise duty and licensing requirements.

Analysis: Tariff Item No. 40 was understood, both from its plain language and the departmental notification relied on, to cover articles of steel which answer the description of furniture. The departmental lists were treated as illustrative of household or comfort-oriented articles and not as extending to industrial equipment merely because of their shape or nomenclature. The disputed trolleys were used in factories for shifting goods and were not ordinary household or clinic articles; the storage bins, pump stands and box with door were likewise not articles used as furniture. The determining test was the ordinary meaning of "furniture" in common parlance, namely articles devised for the convenience or comfort of human beings in the home or office, and the Assistant Collector had placed undue emphasis on the names of the articles rather than their true character.

Conclusion: The articles did not fall within the expression "steel furniture" and were not liable to duty under Tariff Item No. 40; the orders of the excise authorities were unsustainable.

Final Conclusion: The petition succeeded and the impugned excise classification and penalty orders were set aside.

Ratio Decidendi: For excise classification, the true character of the goods must be determined by their ordinary commercial meaning and actual use, and articles that are industrial equipment rather than furniture cannot be brought within a tariff entry for steel furniture merely because of their form or nomenclature.

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