Dear Prakash Sir,
In general Collection of antique coins cannot be covered under personal effects because - COINS CANNOT BE SAID TO HAVE BEEN USED AS SUCH BY THE ASSESSEE which is very much an essential requirement for qualifying as a personal effects.
To qualify for a personal effect the article should be used for personal purposes
Articles must be legitimately and commonly used by assessee - Only those effects can legitimately be said to be personal which pertain to the assessee’s person. In other words, an intimate connection between the effects and the person of the assessee must be shown to exist to render them ‘personal effects’. The enumeration of articles like wearing apparel, jewellery and furniture mentioned by way of illustrations in the definition of ‘personal effects’ also shows that the Legislature intended only those articles to be included in the definition which were intimately and commonly used by the assessee - H.H. Maharaja Rana Hemant Singhji v. CIT [1976] 103 ITR 61 (SC).
{Pls note that the above judgement was pronounced when jewellery was not specifically excluded from the definition of Personal Effects}
Daily usage is not essential - All personal effects need not be used daily. So long as they were meant for personal use, they will have to be considered as personal effects - Jayantilal A. Shah v. K.N. Anantharam Aiyar, CIT [1985] 156 ITR 448 (Bom.)
User only on ceremonial occasion - Merely because in view of nature of property it can be used on ceremonial occasions only, it does not follow that property is not held by assessee for personal use; thus, heirloom jewellery of ex-ruler which were used on ceremonial occasions and accepted as private properties by Ministry of State formed a part of personal effects of assessee-ruler and, therefore, are excluded from definition of term ‘capital asset’ - CIT v. H.H. Maharani Usha Devi [1998] 98 Taxman 309 (SC).
However I think,
IF COINS ARE SUCH WHICH HAVE BEEN USED BY THE ASSESSE IN CEREMONIAL OCASSIONS AND ARE TRANSFEREED AS SUCH (LIKE INDIVIDUALLY) i:e NOT AS A COLLECTION (SINCE IT HAS BEEN SPECIFICALLY EXCLUDED) THEN IT CAN BE TREATED AS PERSONAL EFFECTS.
Can sumone pls clarify my doubt??