Sangeeta Sunil Kadoo v. ITO
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Case in 2 minutes
The reported order concerns additions for property investment. Documentary funding explanations were accepted and the additions were reported as deleted on the evidence.
Case snapshot
Sections / provisions: 69
Questions before the Court / Tribunal
- Property investment and explained sources: The reported order concerns additions for property investment. Documentary funding explanations were accepted and the additions were reported as deleted on the evidence.
Material facts and background
VI. The order seeks to deny submission of documents made by the assessee - During the course of assessment proceedings, assessee had made submission about investment of Rs. 10,00,000/made in the FY 2011-12. Further bank details of FY 2012-13 were also submitted. The order has denied the same. VII. The order has placed selective reliance on the documents and deliberately ignored vital facts mentioned in the same documents, that the order is relied upon, that resulted in presentation twisted facts –Transaction of investment of Rs. 40.95 Lakh was assessed on the basis of sale deed The same document has a mention of agreement to sale which took place in F.Y. 2011-12. The order selectively ignored this important fact. The order is passed as if no details about registered agreement to sale are provided VIII. The order seeks to repeat observations made in first assessment order without applying judicial neutral mind, by ignoring facts of the case and submissions made by assessee - Without going into facts of the case, appeal order has followed same mind-set, as are mentioned in original assessment order, by faulting assessee of not providing documents and information. This is despite the...
At the outset of hearing, the ld. Authorized Representative (AR)
of the assessee invited our attention to page. 68 of the Paper Book which is reproduced below:
It is evident that investment was made in A.Y. 2013–14.
Accordingly assessee is successful in deletion of investment of `. 10,00,000/–.
As regards investment in property, it is pertinent that “during
the course of assessment, it is noted that a AIR information having transaction code-06
Appellant / assessee submissions
The ld. AR vehemently submitted that sale–deed executed is
The ld. AR fairly submitted that he is not pressing other
Revenue / respondent submissions
The judgment copy does not separately set out this component in a distinct section; refer to the full order and the reasoning section below.
Court / Tribunal analysis and reasoning
VI. The order seeks to deny submission of documents made by the assessee - During the course of assessment proceedings, assessee had made submission about investment of Rs. 10,00,000/made in the FY 2011-12. Further bank details of FY 2012-13 were also submitted. The order has denied the same. VII. The order has placed selective reliance on the documents and deliberately ignored vital facts mentioned in the same documents, that the order is relied upon, that resulted in presentation twisted facts –Transaction of investment of Rs. 40.95 Lakh was assessed on the basis of sale deed The same document has a mention of agreement to sale which took place in F.Y. 2011-12. The order selectively ignored this important fact. The order is passed as if no details about registered agreement to sale are provided VIII. The order seeks to repeat observations made in first assessment order without applying judicial neutral mind, by ignoring facts of the case and submissions made by assessee - Without going into facts of the case, appeal order has followed same mind-set, as are mentioned in original assessment order, by faulting assessee of not providing documents and information. This is despite the...
27.08.2012 and transaction amount equal to Rs. 40,95,000/- is available on ITBA system. To furnish the details of such transaction, opportunities is given to the assessee vide notices issued u/s 142(1) and show–cause notice u/s 144 of the I.T. Act, 1961 and assessee is required to furnish details of immovable and movable properties purchased/sold/held by the assessee during the Financial Year 201213. In response, the assessee stated that she had not purchased/sold any immovable property during F.Y. 2012-13. In this regards, notice under section 133(6) of the I.T. Act, 1961 has been issued to SUB
only of `. 35,00,000/–. He has also availed loan of `. 20,00,000/– from State Bank of India. The balance sum of `. 15,00,000/– can be ascribed to her past savings. The explanation is reasonable and may be accepted.
Operative decision and relief
In the result, the appeal of assessee is partly allowed.
Authorities and precedents appearing in the judgment
- No reliable precedent list was extracted automatically; use the full judgment for the citation chain.
This list is machine-assisted from the judgment text and is not a substitute for checking the full citation chain in the PDF.
Ratio and legal principle
The decision turns on Property investment and explained sources. The operative result is classified as Partly Allowed. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Why this judgment matters
The case is relevant to taxpayers, advisers and litigators dealing with Property investment and explained sources. Its practical value lies in the interaction between the statutory text, the evidentiary record and the procedural route followed in this case.
Practitioner action points
- Use the judgment as a fact-specific precedent: match the statutory version, assessment period, procedural stage and evidentiary record before relying on the result.
- Check whether a later High Court/Supreme Court order has affirmed, reversed, distinguished or rendered the decision academic.
- For litigation, attach the full judgment/order to the working paper and cite the paragraph/page supporting the proposition rather than relying on a headnote alone.
Do not over-read this case
- The packaged PDF is not yet an issuing-authority certified copy
- Apply the statutory law applicable to the relevant year; later amendments can change the result.
- Check whether a later High Court or Supreme Court judgment has affirmed, distinguished, reversed or superseded this decision.
How to apply this decision in practice
This ITAT Nagpur decision should be used by matching the client’s facts to the precise controversy in the case—Property investment and explained sources—rather than by relying only on the result. Start with the statutory version applicable to the relevant year and compare it with 69. Amendments, notifications, later Supreme Court/High Court decisions and a different procedural stage can materially change the answer.
For an assessment or litigation file, retain the documents that prove the factual bridge on which the judgment turns: the original notice/order, replies and objections, acknowledgements of filing/service, ledger and banking trail where relevant, contracts or property instruments where relevant, and the complete appellate chronology. If the case succeeds on jurisdiction or natural justice, do not assume the same outcome where the authority cures that defect. If it succeeds on evidence, identify exactly which documents the Court or Tribunal considered persuasive.
For unexplained-income or purchase cases, prepare a source-and-evidence matrix: identity, capacity, genuineness, invoices, e-way/transport records, bank statements, stock/sales reconciliation, third-party statements and cross-examination requests. The evidentiary record is usually what determines whether the precedent truly applies.
Finin2min reliance rule: cite the case for the narrow legal proposition actually decided, record any contrary authority, and attach the full judgment to the working paper or litigation file. This reduces the risk of a headnote or short summary being used outside its factual and statutory context.
Finin2min Judgment Intelligence
Decision support built around the judgment: reliance, fact match, Q&A, section impact, related-case network and practical next steps.
Can I rely on this judgment?
| Authority level | ITAT |
|---|---|
| Reliance effect | Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. |
| Source integrity | A sanitized local full-text judgment copy is packaged; official-primary replacement remains pending. |
| Subsequent history | Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work. |
| Finin2min status | Later-history check open |
Does this case match your facts?
Stronger match when
- Your dispute raises the same core issue: Property investment and explained sources.
- The same statutory provisions or materially equivalent provisions apply: 69.
- Your matter is at a comparable the same procedural and factual stage stage.
- Your documentary/evidentiary record is materially similar to the facts the ITAT Nagpur considered: VI.
- The same legal regime or assessment-period rules relevant to AY 2013-14 apply to your matter.
Weaker / distinguishable when
- A later Supreme Court or jurisdictional High Court ruling changes the legal position.
- The statutory provision was amended for your year or transaction.
- Your evidence, transaction structure, notice chronology or procedural stage differs on a fact the judgment treated as material.
- The case succeeded on a narrow jurisdictional/procedural defect that the authority has cured in your matter.
Questions this judgment answers
What was the main dispute in Sangeeta Sunil Kadoo?
The reported order concerns additions for property investment. Documentary funding explanations were accepted and the additions were reported as deleted on the evidence.
Which facts mattered most to the result?
VI. The order seeks to deny submission of documents made by the assessee - During the course of assessment proceedings, assessee had made submission about investment of Rs. 10,00,000/made in the FY 2011-12.
What did the ITAT Nagpur ultimately decide?
In the result, the appeal of assessee is partly allowed.
What legal principle can be taken from this judgment?
The decision turns on Property investment and explained sources. The operative result is classified as Partly Allowed. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Which provisions should be checked before relying on the case?
The case engages 69. The relevant statutory version for AY 2013-14 should be checked together with any later amendment, notification, circular and controlling higher-court authority.
When is this judgment most useful to a taxpayer or adviser?
The case is relevant to taxpayers, advisers and litigators dealing with Property investment and explained sources . Its practical value lies in the interaction between the statutory text, the evidentiary record and the procedural route followed in this case.
What could make this judgment distinguishable or unsafe to rely on?
The packaged PDF is not yet an issuing-authority certified copy Apply the statutory law applicable to the relevant year; later amendments can change the result. Check whether a later High Court or Supreme Court judgment has affirmed, distinguished, reversed or superseded this decision.
Can this judgment be cited as current law without another check?
Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work. A sanitized local full-text judgment copy is packaged; official-primary replacement remains pending.
Section / provision impact
- 69 — 69 is part of the statutory framework considered in the context of property investment and explained sources. Read the exact provision applicable to the relevant year with the Court/Tribunal reasoning.
How the decision changes your analysis
Before using this authority, frame the issue under 69 and identify the decisive facts/evidence. The result should not be assumed from the case title alone.
The decision turns on Property investment and explained sources. The operative result is classified as Partly Allowed. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work.
Case network: similar and different outcomes
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Related cases with a different result
Related-case links are repository similarity connections, not a claim that one judgment cites or overrules another. Use the cited-authority list and later-history check for formal precedent analysis.
Working-paper citation
Full judgment and source trail
Read / download the clean local judgment copy
| Packaged source class | Sanitized local full-judgment copy; official primary replacement pending |
|---|---|
| Pages | 6 |
| SHA-256 | b2f941af47616c91fd8e45dcaa4e13679494dcf1be9ab57651708deb037e01a3 |
| Local document URL | Open the packaged local document |
| Source authentication | Sanitized local full-text copy - official primary replacement pending |
Related Finin2min guidance
Sections and statute
The numbered references below belong to the statutes and versions identified in this judgment. They are citation labels, not a crosswalk to same-number sections of the Income-tax Act, 2025.
Section 133Section 54