Tariff classification of industrial storage components upheld as parts of steel furniture, subject to the express exclusion for steel angles and channels.

Industrial components used to erect storage racks, cat walks and ladders were construed in their ordinary commercial sense for tariff classification. The Court treated panels, strips, cladding sheets, partition plates and metal shoes as components capable of forming parts of steel furniture where they were used to assemble shelving and storage systems in industrial establishments. The express exclusion for slotted angles and channels made of steel was given full effect, so that exclusion applied only to those items. On that basis, the Revenue's classification under Tariff Item No. 40 was sustained for the articles other than slotted angles and channels.

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Issues: Whether panels, strips, cladding sheets, partition plates, metal shoes and similar articles used for erecting storage racks, cat walks and ladders in industrial establishments were classifiable as parts of steel furniture under Tariff Item No. 40, excluding slotted angles and channels made of steel.

Analysis: The expression "steel furniture" was construed in its ordinary sense, having regard to the wide meaning of furniture as movable articles or fittings used to furnish an establishment. The articles manufactured by the appellant were not merely completed industrial fixtures covered by the administrative circulars relied upon by the assessee, but components used to assemble shelving and storage systems in industrial units. On the facts, the storage structures erected with these components could fall within the tariff description as parts of steel furniture, but the express exclusion for slotted angles and channels had to be given effect.

Conclusion: The articles other than slotted angles and channels made of steel were rightly classifiable under Tariff Item No. 40 as parts of steel furniture, and the exclusion applied only to slotted angles and channels.

Final Conclusion: The appeal failed and the Revenue's classification under the tariff entry was sustained.

Ratio Decidendi: For tariff classification, components used to erect storage systems in industrial establishments may be treated as parts of steel furniture where they answer the tariff description, but express exclusions in the entry must be respected.

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