Excise classification of fabricated steel fittings as furniture failed where they were specially designed for mobile workshop units.

Steel tables and steel cup-boards fabricated for fitting into mobile workshops mounted on trucks were treated as specially designed adjuncts of the mobile service units, not as ordinary general-purpose furniture. Because the Revenue's own notice described them as meant for the mobile service units, the record did not support classification as independent furniture under Tariff Item 40. The excise demand was therefore set aside and the goods were held not exigible to duty as furniture.

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Issues: Whether the steel tables and steel cup-boards fabricated for fitting into mobile workshops mounted on trucks were liable to excise duty as furniture under Tariff Item 40, or were to be treated as specially designed adjuncts of the mobile service units.

Analysis: The Revenue's own show cause notice stated that the steel tables and cup-boards were meant for mobile service units. On that basis, they were not general-purpose furniture, but components fabricated for integration with the mobile workshops. The record therefore did not justify classifying them as independent furniture liable under Tariff Item 40.

Conclusion: The steel tables and steel cup-boards were not exigible to duty as furniture under Tariff Item 40 and the appeal was decided in favour of the assessee.

Final Conclusion: The demand of excise duty on the steel tables and steel cup-boards was set aside and the assessee succeeded.

Ratio Decidendi: Goods fabricated as specially designed adjuncts for a specific mobile unit cannot be classified as ordinary furniture for excise purposes merely because they may resemble general-purpose items.

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