Wealth-tax meaning of "jewellery" excluded plain gold ornaments before 1 April 1972, leaving them outside the exemption scope.

For assessment years prior to 1 April 1972, the expression "jewellery" in section 5(1)(viii) of the Wealth-tax Act, 1957 did not include gold ornaments unless they were studded with precious or semi-precious stones. Applying the Full Bench view, the High Court held that plain gold ornaments fell outside the scope of the exemption-related term "jewellery" for that period, and the reference was answered against the assessee.

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Issues: Whether, for assessment years prior to 1 April 1972, the expression "jewellery" in section 5(1)(viii) of the Wealth-tax Act, 1957 included gold ornaments not studded with precious or semi-precious stones.

Analysis: The reference was decided in the light of the Full Bench opinion that, for assessment years prior to 1 April 1972, the term "jewellery" did not extend to gold ornaments unless they were studded with precious or semi-precious stones. The Court adopted that view and answered the referred question accordingly.

Conclusion: For assessment years prior to 1 April 1972, gold ornaments not studded with precious or semi-precious stones were not covered by the expression "jewellery" in section 5(1)(viii) of the Wealth-tax Act, 1957, and the answer was against the assessee.

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