Furniture classification depends on design and identity, not mere floor placement; wooden storage boxes stayed articles of wood.

Wooden storage and transport boxes were held not to be furniture under Heading 94.03 merely because they could be placed on the floor. Classification depended on whether the article was designed and identifiable as furniture, not on its physical form or the possibility of floor placement. Applying Section Note 2 to Chapter 94, the tribunal treated boxes made for a specific storage function as articles of wood rather than furniture, and rejected a reading that would extend furniture classification to ordinary containers. The Revenue's challenge failed and the classification in favour of the assessee was sustained.

---

---

Issues: Whether wooden boxes manufactured for storage and transportation of goods were classifiable as articles of wood under Heading 4410.90 or as furniture under Heading 94.03.

Analysis: The classification turned on the meaning of furniture and the effect of Section Note 2 to Chapter 94. The boxes were not specially designed as furniture merely because they could be placed on the ground. The reasoning accepted that articles fabricated for a specific storage function do not become furniture simply on account of their physical form or the possibility of being kept on the floor. The interpretation urged by the Revenue would extend furniture classification too broadly to ordinary containers and boxes.

Conclusion: The wooden boxes were not classifiable as furniture under Heading 94.03 and were to be classified under the residual article of wood heading.

Final Conclusion: The Revenue's challenge to the classification failed, and the lower order in favour of the assessee was sustained.

Ratio Decidendi: An article does not become furniture merely because it can be placed on the floor; classification depends on whether it is designed and identifiable as furniture rather than as a container or box for a specific function.

---