Classification of steel components turned on special shape or design; multi-use goods fell outside the steel furniture exemption exception.

Steel panels, partition plates and shelves were considered in relation to Tariff Item 40 and Notification No. 52/70, which withheld exemption only where parts of steel furniture had a special shape or design making them clearly identifiable as essential components. The decisive point was whether the goods were specially adapted only for steel furniture; they were found to have multiple industrial uses, including catwalks, ladders and mezzanine floors, and the Department failed to prove the required special shape or design. The Board's clarification on unassembled furniture did not control the scope of the later exemption notification. On that basis, the goods were treated as classifiable under Tariff Item 68 rather than as exempt-denied parts of steel furniture.

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Issues: Whether steel panels, partition plates and shelves were classifiable as parts of steel furniture under Tariff Item 40 and denied exemption under Notification No. 52/70, or whether they were classifiable under Tariff Item 68.

Analysis: Tariff Item 40 covered steel furniture and parts of such steel furniture, but Notification No. 52/70 exempted parts other than those given a special shape or design so as to make them clearly identifiable as essential components of steel furniture. The deciding consideration was whether the goods, on their own shape and design, were specially adapted only as essential components of steel furniture. The goods in question were found to have multiple uses and to be suitable not only for furniture but also for other industrial structures such as catwalks, ladders and mezzanine floors. The Department had not shown that they had been given such a special shape or design as to make them clearly identifiable as essential components of steel furniture. The Board's clarification on unassembled furniture did not govern the scope of the later exemption notification.

Conclusion: The goods were not classifiable as parts of steel furniture under Tariff Item 40 for denial of exemption and were correctly classified under Tariff Item 68; the appeal failed.

Ratio Decidendi: Where goods have multiple industrial uses and are not shown to have a special shape or design making them clearly identifiable as indispensable components of steel furniture, they do not fall within the taxable exception in the exemption notification for parts of steel furniture.

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