Tariff classification of kitchen tables and steel stands favoured Heading 94.03 as furniture, not household articles.

Kitchen tables, work tables, service counters and stainless steel stands were held to fall under Heading 94.03 as furniture or special-use furniture, rather than Heading 73.23 as iron or steel household articles. The classification turned on the tariff scope and the HSN notes, which indicate that Heading 73.23 is confined to kitchen, table or household articles, while Heading 94.03 covers furniture for general or special use and is not limited to ordinary domestic furniture. On that interpretive basis, the goods were classified under Heading 94.03.

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Issues: Whether kitchen tables, work tables, service counters and stainless steel stands are classifiable under Heading 73.23 or under Heading 94.03 of the Central Excise Tariff.

Analysis: Heading 73.23 covers table, kitchen or other household articles of iron or steel, as elucidated by the HSN, and extends to articles used for kitchen, table or household purposes. Heading 94.03 covers other furniture and parts thereof, including furniture for general use and for special uses, and the HSN note shows that it is not confined to ordinary domestic furniture. The disputed goods, being tables, counters and stands used on the floor and answering the description of furniture or special-use furniture, are not shown to fall within the restricted range of kitchen or household articles contemplated by Heading 73.23. In tariff interpretation, the HSN notes properly guide classification where the tariff is aligned to the HSN.

Conclusion: The goods are classifiable under Heading 94.03 and not under Heading 73.23, and the Revenue's appeal succeeds.

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