Composite appeal against multiple demand notices is not maintainable where each notice must be separately challenged under the appellate rules.

Under Rule 7(1) of the Textiles Committee (Appeal to the Tribunal) Rules, 1976, each appeal had to be accompanied by the relevant notice of demand, so a single composite appeal against distinct demand notices for different periods was not maintainable. Rule 8 was also held unavailable where the demand was based on the appellant's own returns and the record showed prior awareness of the demand, so the complaint of absence of opportunity failed. The Tribunal therefore rejected the procedural objections and upheld the demand notices in principle, resulting in dismissal of the appeal.

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Issues: (i) Whether an appeal against more than one demand notice by clubbing them in a single appeal was maintainable under Rule 7(1) of the Textiles Committee (Appeal to the Tribunal) Rules, 1976; (ii) Whether Rule 8 could be invoked to challenge the demand notices on the ground of absence of opportunity.

Issue (i): Whether an appeal against more than one demand notice by clubbing them in a single appeal was maintainable under Rule 7(1) of the Textiles Committee (Appeal to the Tribunal) Rules, 1976.

Analysis: Rule 7(1) required each appeal to be accompanied by the notice of demand regarding the assessment appealed against. The demand notices in question were distinct and related to different periods. On that framework, a single appeal challenging multiple demand notices did not satisfy the prescribed procedure.

Conclusion: The appeal by clubbing multiple demand notices was not maintainable and the objection was decided against the appellant.

Issue (ii): Whether Rule 8 could be invoked to challenge the demand notices on the ground of absence of opportunity.

Analysis: The demand notices were founded on returns filed by the appellant, and the record indicated prior awareness of the demand. On that basis, Rule 8 was held inapplicable to the case.

Conclusion: Rule 8 did not apply, and the challenge on the ground of absence of opportunity failed.

Final Conclusion: The Tribunal upheld the demand notices in principle, rejected the procedural challenge, and dismissed the appeal.

Ratio Decidendi: Where the appellate rules require an appeal to be filed against a specific notice of demand, a composite appeal against multiple demand notices is not maintainable, and a separate procedural safeguard cannot be invoked where the demand arises from the assessee's own returns and the governing rule is inapplicable.

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