Separate appeals for each bill of entry were required where each assessment was challenged individually before the Commissioner (Appeals).

Rule 6A of the CESTAT Procedure Rules, 1982 ordinarily permits one memorandum of appeal even where an impugned order covers multiple bills of entry, but separate memoranda are required where the order-in-appeal relates to more than one order-in-original. On the facts, each of the 84 bills of entry had been challenged separately before the Commissioner (Appeals), so they were treated as distinct assessment orders for appeal purposes. A precedent relied on by the appellant was distinguished as factually different. Separate appeals were therefore required for each bill of entry, and additional appeals had to be filed.

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Issues: Whether a single appeal was sufficient against an order-in-appeal disposing of disputes relating to 84 bills of entry, or whether separate appeals were required for each bill of entry.

Analysis: Rule 6A of the CESTAT Procedure Rules, 1982 provides that one memorandum of appeal ordinarily suffices notwithstanding the number of bills of entry or similar documents dealt with in the impugned order. The explanation, however, requires separate memoranda where the impugned order-in-appeal is with reference to more than one order-in-original. On the facts, the 84 bills of entry had each been challenged separately before the Commissioner (Appeals), so they were treated as distinct assessment orders for the purpose of appeal filing. The reliance on a different precedent was held inapplicable because the factual matrix was not the same.

Conclusion: A separate appeal was required for each of the 84 bills of entry, and the appellant was directed to file the additional appeals.

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