2022 (1) TMI 1143

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....cts, all these appeals were heard together and are being disposed of by this common order, for the sake of convenience. 2. All these assessees are challenging the orders passed by Ld CIT(A) in dismissing the appeals without deciding the issues contested before him on merits. They have also raised grounds on merits of addition. 3. The Ld A.R submitted that the assessment of the year under consideration was reopened by the AO u/s 147 of the Income-tax Act,1961 ['the Act' for short] in order to assess capital gains arising on sale of land. The notices were issued in the individual status of the assessees. All these assessees contended before the AO that there was actually no transfer of land and hence capital gain is not assessable. ....

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....he A.O. has completed the assessment in the individual status assessing the proportionate share of capital gain arising on sale of land. It is the contention of the assessees that the land belonged to HUF of the respective assessees and hence capital gain, if any, is assessable in the hands of the HUF only. Accordingly, as advised by the tax consultant, these assessees have filed appeals mentioning the PAN of HUF. The Ld. A.R. submitted that one of the grounds raised before Ld. CIT(A) was that the capital gain, if any is assessable in the hands of the HUF only and hence the same has prompted the tax consultant to file appeal mentioning PAN of HUF. Accordingly, the Ld. A.R. submitted that mentioning of PAN of HUF in Form No.35 is a mistake w....