JUDGMENT K. S. PARIPOORNAN, J. - The revision-petitioner is an assessee under the Kerala General Sales Tax Act, 1963. The respondent is the Revenue. We are concerned with the assessment year 1982-83. The assessee is a manufacturing company. Amongst others, it manufactures and sells slotted angles and panels. They are exclusively made of iron and steel. The Revenue sought to assess the turnover of the said goods, under entry 145 of the First Schedule to the Kerala General Sales Tax Act, which runs as follows : "Safes, almirahs and furniture made of iron or steel." (The entry as it stood during the relevant assessment year 1982-83 and before the amendment by Kerala Finance Act, 1984). The Appellate Tribunal held that angles and panels will be taken in by the word "furniture" occurring in entry 145 of the First Schedule to the Kerala General Sales Tax Act, Aggrieved by the aforesaid decision of the Sales Tax Appellate Tribunal dated 26th September, 1988, the assessee has come up in revision. 2. We heard counsel for the assessee-revision-petitioner, Mr. Ramachandran Nair of M/s. Menon and Pai and counsel for the Revenue-respondent, learned senior Government Pleader Mr. N. N. Divakaran Pillai. Counsel for the assessee submitted that the approach and conclusion of the Sales Tax Appellate Tribunal to hold that angles and panels sold by the assessee are used usually in offices for the purposes of keeping files, papers, etc., and even if they are separately purchased the ultimate use of the items is as an article of convenience, and for furnishing the place of business or an office and in this view it is an article of furniture, is fallacious. It was argued that in the context, the word "furniture" made of iron or steel, can take in only an article which is used or usable, as a furniture, as such. The angles and panels though it may be made use of for various purposes like making racks, ladders, etc., cannot be called an article of furniture within the meaning of entry 145 of the First Schedule to the Kerala General Sales Tax Act. The angles and panels though it may be made use of for various purposes like making racks, ladders, etc., cannot be called an article of furniture within the meaning of entry 145 of the First Schedule to the Kerala General Sales Tax Act. On the other hand, counsel for the Revenue submitted that when the slotted angles and panels are used for making racks, ladders, etc., they are used as "furniture" and so the slotted angles and panels will be taken in by the word "furniture" occurring in entry 145 of the First Schedule to the Kerala General Sales Tax Act. 3. Entries 143 to 145 of the First Schedule to the Kerala General Sales Tax Act occurred under the heading "furniture". They are as follows : "THE FIRST SCHEDULE Goods in respect of which single point tax is leviable under sub-section (1) or sub-section (2) of section 5. ------------------------------------------------------------------------ Sl. Description of goods Point of levy Rate of tax No. ------------------------------------------------------------------------ Furniture 143 Upholstered furniture At the point of first sale the State by a dealer who is liable to tax under section 5 10 143A Sofa sets, dressing tables and furniture of all types made of timber, rattan or bamboo do. 7 144 Upholstered furniture supported on steel frames. do. 12 145 Safes, almirahs and furniture made of iron or steel do. 12." ------------------------------------------------------------------------ (Before the amendment by Kerala Finance Act, 1984) All articles referred to, are end-products used as articles of furniture, as such. It cannot admit of any doubt that in common parlance or in the commercial world the slotted angles and panels separately sold by the revision-petitioner is not known or understood as a furniture made of iron or steel and usable as such. The fact that slotted angles and panels can be so manipulated, to make a rack or ladder, which may be called as an item of furniture, cannot be a factor to hold that the word "furniture" made of iron or steel will take within its fold, even the component part or parts thereof. Accordingly, we are of the view that the Sales Tax Appellate Tribunal was in error in holding that slotted angles and panels made of iron or steel sold by the revision-petitioner will come within entry 145 of the First Schedule to the Kerala General Sales Tax Act. Accordingly, we are of the view that the Sales Tax Appellate Tribunal was in error in holding that slotted angles and panels made of iron or steel sold by the revision-petitioner will come within entry 145 of the First Schedule to the Kerala General Sales Tax Act. The context in which the said entry occurs does not support the stand taken by the Revenue. 4. Entry 145 of the First Schedule to the Kerala General Sales Tax Act was amended by the Kerala Finance Act, 1984, which took effect from 1st April, 1984. The entry as amended reads as follows : "145. Safes, almirahs and furniture or parts thereof made of iron or steel." The amendment was brought in with a view to rope in the various parts which will finally make a furniture or result in producing or assembling a furniture. Before the amendment, the entry is not capable of taking in various components sold separately. 5. The three decisions brought to our notice are distinguishable. In Chandan Metal Products Pvt. Ltd. v. State of Gujarat [1969] 23 STC 29 (Guj), the items involved were shelving racks and binstaks sold as such. Shelving rack sold can be used as such in an office or an industrial organisation for the purpose of keeping files, etc. Binstak was held to be a part of office furniture or a furniture of a place of business. Since both of them by themselves were capable of being used as articles of furniture, the court held that they will come within the relevant entry "furniture" occurring in entry 44H of Schedule C of the Bombay Sales Tax Act, 1959. In Deputy Commissioner of Agricultural Income-tax and Sales Tax v. E. V. Industries [1974] 33 STC 308, the question that arose for consideration was whether hospital equipments will be taken in by the word "furniture" made of iron and steel ? A Bench of this Court held that hospital equipments though meant for the peculiar needs of a hospital and somewhat peculiar in physical features of height and girth and other attributes, will still be "furniture made of iron and steel". But, it should be noted that the articles dealt within that case were used and usable as furniture as such. A Bench of this Court held that hospital equipments though meant for the peculiar needs of a hospital and somewhat peculiar in physical features of height and girth and other attributes, will still be "furniture made of iron and steel". But, it should be noted that the articles dealt within that case were used and usable as furniture as such. Still later in Commissioner of Sales Tax v. Dhingra and Company [1979] 43 STC 268 (All.), the question that arose was whether the trestles used for resting guns in armouries, gunsmith's shops or some homes can be called "furniture"? The court held that trestles was used as a stand for resting guns in armouries, etc., and since it was ordinarily so used and accepted as such, it will be taken in by the word "furniture". The said decisions are distinguishable. The decisions aforesaid did not deal with components which went into result in the end-product or the assembled product. 6. In this view of the matter, we are of the opinion that the Sales Tax Appellate Tribunal was in error in holding that angles and panels will come within entry 145 of the First Schedule to the Kerala General Sales Tax Act before its amendment by the Kerala Finance Act, 1984. The said goods will come only within entry 45 of the First Schedule, as "iron and steel articles not mentioned elsewhere in the First Schedule or the Second Schedule". We hasten to add that the legal position stated by us is only for the period before the amendment of the relevant entry by the Kerala Finance Act, 1984. 7. We set aside the order passed by the Sales Tax Appellate Tribunal dated 26th September, 1988, on this aspect. The revision is allowed. The assessing authority is directed to amend the assessment in accordance with this judgment Petition allowed.