Specially fabricated tractor seat assemblies are not steel furniture and do not qualify for exemption under the tariff notification.

Steel seat assemblies made for tractors were treated as specially fabricated components for a vehicle function, not as "steel furniture" under Tariff Item 40. The Tribunal applied the ordinary commercial meaning of furniture and held that an article must be an item of convenience or decoration, ordinarily bought and sold as such, and not a specialised fitting, to fall within that item. Because the exemption in Notification No. 91/68 was limited to steel seats and chairs classifiable under Tariff Item 40 for specified transport uses, it could not extend to tractor seat assemblies. Classification under Tariff Item 68 was therefore maintained.

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Issues: Whether steel seat assemblies manufactured for tractors are classifiable under Tariff Item 40 as steel furniture, or under Tariff Item 68 as residuary goods, and whether they qualify for exemption under Notification No. 91/68 dated 30-4-1968.

Analysis: The Tribunal held that tractor is an automobile, but that fact by itself does not bring the seat assembly within Tariff Item 40. For classification as furniture, the article must answer the ordinary understanding of furniture: an item of convenience or decoration, ordinarily bought and sold as such, and not fabricated to perform a special function. The tractor seat assembly was found to be specially designed for use in tractors, not to be a movable piece of furniture, and not fit for classification as steel furniture under Tariff Item 40. Since the exemption in Notification No. 91/68 applies only to steel seats and chairs falling under Tariff Item 40 and designed for use in automobiles, railway carriages and aircraft, the notification could not be invoked for the tractor seat assembly.

Conclusion: The steel seat assembly for tractors is not classifiable under Tariff Item 40 and is not entitled to exemption under Notification No. 91/68; the classification under Tariff Item 68 was upheld and the appeal failed.

Ratio Decidendi: An article specially fabricated for a particular vehicle function is not steel furniture under Tariff Item 40 unless it satisfies the ordinary commercial understanding of furniture, and an exemption confined to goods falling under that item cannot be extended to non-qualifying goods.

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