Separate appeals required for multiple Bills of Entry under CESTAT procedure when one common order covers distinct assessments.

Rule 6A of the CESTAT Procedure Rules, 1982 allows a single memorandum of appeal only when one common order is under challenge; where the impugned appellate order relates to more than one order-in-original, separate memoranda are required for each underlying order. Because the common order-in-appeal covered 93 Bills of Entry and each Bill of Entry constituted a separate assessment, the Revenue was required to file 93 separate appeals. A single appeal was therefore procedurally incompetent and not maintainable, leaving the impugned order undisturbed on that threshold ground.

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Issues: Whether one appeal filed by the Revenue was maintainable against a common order-in-appeal disposing of disputes relating to 93 Bills of Entry.

Analysis: Rule 6A of the CESTAT Procedure Rules, 1982 permits a single memorandum of appeal where one common order is under challenge, but its Explanation requires as many memoranda of appeal as there are orders-in-original where the impugned order-in-appeal is passed with reference to more than one order-in-original. The common appellate order covered 93 assessments, each Bill of Entry constituting an assessment order in itself. On that footing, the challenge to each assessment had to be made separately, and the filing of a single appeal was contrary to the procedural mandate.

Conclusion: The appeal was not maintainable and had to be filed as 93 separate appeals.

Final Conclusion: The Revenue's challenge failed at the threshold for want of the requisite number of appeals, and the impugned order was left undisturbed on this procedural ground.

Ratio Decidendi: When a common order-in-appeal covers multiple Bills of Entry or assessments, the appellant must file separate appeals corresponding to each underlying order-in-original in terms of Rule 6A of the CESTAT Procedure Rules, 1982.

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