Composite orders require each appeal to meet the monetary threshold, while Cenvat credit claims need service-wise factual findings.

In a composite order disposing of multiple appeals or show-cause notices, each appeal must be tested separately against the monetary threshold under the litigation policy; appeals below the prescribed limit are not maintainable and cannot proceed. On the Cenvat credit issue, entitlement to credit on disputed input services requires service-wise findings based on the actual facts, and reliance on case law without matching the factual matrix is insufficient. The order was therefore sustained only to the extent of the monetary-limit objection, while the surviving matter was remanded for fresh adjudication with specific findings on each disputed service.

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Issues: (i) Whether the revenue appeals falling below the prescribed monetary threshold in a composite order were maintainable under the litigation policy. (ii) Whether the Commissioner (Appeals) had given adequate findings on the admissibility of Cenvat credit on the disputed services, or whether the matter required remand for fresh consideration.

Issue (i): Whether the revenue appeals falling below the prescribed monetary threshold in a composite order were maintainable under the litigation policy.

Analysis: The applicable circular clarifies that the term "case" in the monetary-limit instructions must be understood in the context of reducing litigation. Where a composite order disposes of more than one appeal or show-cause notice, each appeal is to be treated as a separate case and tested independently against the monetary threshold. On that basis, the appeals that did not satisfy the prescribed limit could not be pursued further.

Conclusion: The four appeals below the monetary threshold were not maintainable and stood dismissed.

Issue (ii): Whether the Commissioner (Appeals) had given adequate findings on the admissibility of Cenvat credit on the disputed services, or whether the matter required remand for fresh consideration.

Analysis: The order under challenge dealt with the disputed services in a cursory manner and relied on case law without examining whether the factual matrix of those decisions matched the present case. Since entitlement to credit on input services depends on the nature of the goods manufactured and the services rendered, the adjudicating authority had to record service-wise findings based on the facts of the case.

Conclusion: The order was set aside for the remaining appeal and the matter was remanded to the Commissioner (Appeals) for specific findings on each disputed service.

Final Conclusion: The revenue succeeded in part on the monetary-limit objection, while the surviving appeal was sent back for fresh adjudication on the merits of the Cenvat credit claim.

Ratio Decidendi: In a composite order, each appeal must independently satisfy the monetary threshold under the litigation policy, and credit eligibility on input services requires service-wise findings grounded in the facts of the case.

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