Consolidated tax appeals may be filed together, but separate court fee applies to each underlying cause of action.

An appeal under section 260A may be filed in consolidated form against a Tribunal order disposing of multiple appeals for different assessment years or assessees, because consolidation is permissible for convenience. However, each assessment year and each assessee gives rise to an independent cause of action, so the consolidated appeal continues to represent distinct underlying appeals. Court fee is therefore payable separately for each appeal or cause of action included in the consolidated filing, and the Court's power under the Court Fees Act and section 149 CPC extends only to securing payment within time, not to waiving the liability.

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Issues: (i) Whether one appeal under section 260A of the Income-tax Act, 1961 lies against a consolidated order of the Appellate Tribunal disposing of multiple appeals for different assessment years or different assessees; (ii) Whether court fee is payable separately for each appeal or cause of action comprised in such consolidated appeal.

Issue (i): Whether one appeal under section 260A of the Income-tax Act, 1961 lies against a consolidated order of the Appellate Tribunal disposing of multiple appeals for different assessment years or different assessees.

Analysis: The appellate jurisdiction under section 260A is distinct from the advisory jurisdiction involved in references under section 256. A consolidated Tribunal order, though common in form, is treated as disposing of each underlying appeal separately because each assessment year and each assessee gives rise to an independent cause of action. The procedural practice followed in reference matters could not be imported bodily into appeals, yet consolidation remained permissible as a matter of convenience.

Conclusion: One consolidated appeal was held maintainable against a consolidated Tribunal order, including where it covered multiple assessment years or assessees.

Issue (ii): Whether court fee is payable separately for each appeal or cause of action comprised in such consolidated appeal.

Analysis: Since a consolidated appeal represents several distinct causes of action, the court fee obligation attaches to each such cause of action. The Court held that it had no power to remit or reduce court fee, and the relevant provisions of the Court Fees Act and section 149 of the Code of Civil Procedure, 1908 could be used only to secure payment within time, not to waive the liability.

Conclusion: Separate court fee was held payable for each appeal or assessment year and for each assessee included in the consolidated appeal.

Final Conclusion: The Court permitted filing of one consolidated appeal for convenience, but treated it as representing multiple appeals and separate causes of action, with corresponding liability to pay court fee in respect of each.

Ratio Decidendi: An appeal under section 260A from a consolidated Tribunal order may be filed in consolidated form, but it continues to represent distinct underlying appeals and causes of action, so court fee is exigible separately for each such cause of action.

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