The judgment of the court was delivered by

GOVINDAN NAIR, AG. C.J. - The question is how the words "furniture made of iron and steel" in item No. 17 in the First Schedule to the Kerala General Sales Tax Act, 1963, for short, the Act, must be interpreted. Item 17 in its entirety reads as follows :

"17. Safes, almirahs and furniture made of iron and steel."

The goods falling within the item are liable to tax at the first point of sale in the State by a dealer who is liable to tax under section 5 of the Act at the rate of 12 per cent of the turnover.

2. The Tribunal took the view that the goods described in the statement dated 22nd November, 1971, filed by the assessee are not goods falling within item 17 of the First Schedule. For easy reference, that statement is attached hereto, as an appendix.

3. Certain principles are now well-settled : In fiscal statutes, words used must be understood according to their popular sense. Scientific or technical meanings are not generally attributed to words in such statutes. The dictionary meaning of the words need not necessarily be applied invariably. (See the Full Bench decision of this Court in Krishna Iyer v. State of Kerala ([1962]