Rashmi Niranjan Mehta Vs ITO (ITAT Mumbai)
The Mumbai Income Tax Appellate Tribunal (ITAT) heard an appeal filed by the assessee against the order dated 03.07.2025 passed by the Commissioner of Income Tax (Appeals) for AY 2013-14. The dispute related to denial of deduction under Section 54F, treatment of sale proceeds from gold ornaments and silver utensils as income from other sources, and disallowance of deductions under Sections 24 and 80C.
The assessee had filed her return declaring income of ₹57,140. During assessment proceedings, the Assessing Officer noted that the assessee had claimed exemption under Section 54F on capital gains arising from sale of gold ornaments and silver utensils amounting to ₹29.90 lakh. The assessee explained that she had sold approximately 1001.4 grams of gold ornaments and 13,068 grams of silver utensils received during her marriage in 1992 and on subsequent occasions from family members and relatives.
The assessee further stated that the gold and silver items were reflected in her capital account and balance sheet as on 31.03.1993. However, the Assessing Officer rejected the explanation on the ground that the assessee had not filed any wealth tax return disclosing the ornaments and had failed to establish acquisition and ownership of the jewellery. The entire sale proceeds of ₹29.90 lakh were therefore treated as income from other sources, and exemption under Section 54F was denied.
