Judgment :- V.V. Kamat, J. This revision raises a short question, which is to be basically answered on the basis of application of commonsense of understanding, if not, application of the dictionary meaning. 2. With regard to the final assessment completed under the provisions of the Kerala General Sales Tax Act, 1963, for the assessment year 1989-90, the petitioner-assessee preferred appeal dispute regarding the rate of tax applicable to three items - T.Y. stand, fridge stand and its top - contending that these are items of furniture and therefore, taxable at the point of first sale in the State. It cannot be disputed that these three items could not be understood separately. T. V. stand by itself has no independent existence. Similarly fridge stand and its top also cannot be understood by themselves. They are to be considered as accessories of the two items - T. V. and fridge and therefore the authorities held these items as general items taxable at multi-point at 5 per cent. 3. The appellate authority has found on facts that these three items are special items exclusively meant for using along with T. V. and fridge only, and therefore, cannot be generally held as furniture. 4. The learned counsel firstly relied on Entry No. 81 which is to the following effect: "Furniture of all kinds other than those coming under Entry 82". Entry No. 82 is as follows: "Furniture made of bamboo or rattan". Obviously the situation will be governed by Entry No. 81, which states and includes furniture of all kinds for our purpose. 5. The learned counsel brought to our notice the decision of this Court.
Entry No. 82 is as follows: "Furniture made of bamboo or rattan". Obviously the situation will be governed by Entry No. 81, which states and includes furniture of all kinds for our purpose. 5. The learned counsel brought to our notice the decision of this Court. [1974] 33 STC 308 (Ker.) (Deputy Commissioner of Agricultural Income-tax and Sales Tax v. E.V. Industries, Angamaly), We have gone through the said decision where Item No. 17 in the First Schedule to the Kerala General Sales Tax Act, 1963, then applicable, refers to the words "furniture made of iron and steel" in regard to which it is held that these words must be read with safes and almarahs made of iron and steel and in the context in which those words occurred, it is held that there is no justification for giving any limited meaning to those words in the context of the dispute therein that these items could not be held as limited to house hold furniture alone and would have to be understood to include hospital equipments satisfying similar description.- The Court found the words in regard there to referred to above as not sufficiently clear. 6. It is in the context of this position, finding that the words "furniture made of iron and steel" are not sufficiently clear as to whether it is referable to household furniture or it can also include furniture in the shape of hospital equipments which was the controversy that was required to be understood and interpreted by the court in the said decision cited. In Paragraph 5 of the said judgment on which the learned counsel strenuously relies, the dictionary meaning is found as follows: "bouvier slaw Dictionary gives an elaborate analysis of the meaning of the word 'fiinsiture". It starts by saying furniture is "personal chattels in the use of a family' and v the word relates, ordinarily, to movable personal chattels'. Then it proceeds to say, Mt is very general, both in meaning and application; and its meaning changes, so as to take the colour of, or be in accord with, the subject to which it is applied". 7. Even taking into consideration, the definition as to be found applied by the Court in connection with the controversy, it would be of no help.
7. Even taking into consideration, the definition as to be found applied by the Court in connection with the controversy, it would be of no help. The learned counsel contended that the furniture has to be understood as personal chattels in the use of a family and has to be relating ordinarily to movable personal chattels. 8. In our judgment, "furniture" has to be understood as considered above. A T.V. set and a fridge can never be understood as items of furniture, but are generally understood as electric gadgets. The items in regard to which dispute is raised will have to be understood as accessories thereto there being crystal clear position that these items by themselves have no meaning and use in the context as independent items. 9. In our judgment the petitioner is not entitled to contend for acceptance mat these items would have to be considered as items of furniture. The decision cited does not govern the situation under consideration before us. For the above reasons, the revision case stands dismissed.