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Issues: Whether a single appeal could be filed against two Orders-in-Original merged in one Order-in-Appeal, and whether the additional court fee collected in the defect memo was refundable.
Analysis: The Tribunal held that the cited decisions dealing with the number of appeals by reference to show-cause notices were not applicable. It applied the Larger Bench view that the number of appeals is determined by the number of adjudicating orders, not by the manner in which they are dealt with in appeal. Since there were two adjudication orders, two appeals were required, and the defect memo demanding additional court fee was in law.
Conclusion: The appellant was required to file two appeals, and the court fee was rightly collected. The request for refund of the additional court fee was rejected.