Held, allowing the appeal, that under section 2(14) of the Act “capital asset” means property of any kind held by the assessee, whether or not connected with his business or profession, but does not include stock-in-trade, raw materials held for the purpose of business or profession. The receipt of Rs. 70,38,450 on relinquishment of the assessee’s share from firm was a capital gains wherein the claim of reinvestment on residential flats of Rs. 26,52,000 is an allowable deduction under section 54F of the Act. Referred, CIT v. Mansukh Dyeing and Printing Mills (2022) 449 ITR 439 (SC), CIT v. A.N.Naik Associates (2004) 265 ITR 346 (Bom)(HC) (AY.2013-14)