Tariff classification of carriage trolleys turned on functional use, with wheeled movement treated as incidental, not as vehicles.

Tariff classification of carriage trolleys depended on their nature, design, construction and functional utility, not on the fact that they were wheeled or movable. The trolleys were used within industrial premises for storing, hanging, keeping and carrying clothes, with movement only incidental to that purpose. Castors did not convert them into non-mechanically propelled vehicles, and Chapter 87 was confined to transport-type conveyances. In common parlance and commercial understanding, the articles answered the description of furniture and were correctly classifiable under Heading 94.03 rather than Heading 87.16.

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Issues: Whether the carriage trolleys manufactured by the assessee were classifiable under Heading 87.16 as non-mechanically propelled vehicles or under Heading 94.03 as other furniture.

Analysis: The classification had to be determined by the nature, design, construction and functional utility of the goods, and not merely by the fact that they were wheeled or capable of being moved. The trolleys were meant for storing, hanging, keeping and carrying clothes within industrial or allied premises, and their movement was only incidental to that function. The presence of castors did not make them vehicles. In tariff interpretation, the relevant consideration was the essential character of the article in common parlance and commercial understanding. Goods used for convenience, storage and handling in premises could still answer the description of furniture, and specialised utility articles were not excluded from that category merely because of their particular design or use. The scheme of Chapter 87 showed that the expression vehicles contemplated transport-type conveyances, which these trolleys were not.

Conclusion: The trolleys were not vehicles under Heading 87.16 and were correctly classifiable as other furniture under Heading 94.03, against the assessee.

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