Independent assessment orders under Rule 6A require separate appeals for each Bill of Entry challenge.

Rule 6A of the CESTAT Procedure Rules, 1982 was applied to hold that each Bill of Entry is an independent assessment order, so the maintainability of an appeal must be tested Bill of Entry-wise. Where the impugned matter concerns multiple original assessment orders, the Explanation to Rule 6A requires separate appeals to match the number of assessment orders challenged; a consolidated appeal is not sufficient merely because the disputes arise from similar facts or a common order-in-appeal. On that basis, the Revenue's four appeals against assessment orders relating to 399 Bills of Entry were held not maintainable, and separate appeals were required for each assessment challenged.

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Issues: Whether the Revenue's 4 appeals challenging assessment orders relating to 399 Bills of Entry were maintainable under Rule 6A of the CESTAT Procedure Rules, 1982.

Analysis: Rule 6A permits a single memorandum of appeal where one order deals with multiple bills of entry, but its Explanation requires as many appeals as there are orders-in-original where the impugned order-in-appeal relates to more than one original order. The assessment of each Bill of Entry is treated as an independent assessment order. The appeal requirement is therefore to be tested Bill of Entry-wise, and the number of appeals must correspond to the number of assessment orders challenged. The cited authorities on Rule 6A and the litigation policy were applied to hold that the monetary threshold and appeal maintainability cannot be aggregated across multiple independent assessments.

Conclusion: The 4 Revenue appeals were not maintainable, and separate appeals were required for the individual Bills of Entry.

Ratio Decidendi: Where each Bill of Entry constitutes a separate assessment order, the appellant must file a corresponding appeal for each such assessment challenged; a consolidated appeal is not maintainable merely because the disputes arise from similar facts or a common order-in-appeal.

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