Separate appeals required for each Bill of Entry when a common appellate order covers distinct assessment orders.

Rule 6A of the CESTAT Procedure Rules permits one memorandum of appeal only where a common order covers multiple Bills of Entry, but a separate appeal is required where the impugned order-in-appeal relates to more than one order-in-original. Each Bill of Entry was treated as an independent assessment order, and the common appellate order disposed of separate appeals concerning 13 Bills of Entry. The Tribunal held that the Revenue's single appeal was not maintainable and that 13 separate appeals were required, leaving the appellate relief in favour of the importer undisturbed.

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Issues: Whether a single appeal filed by the Revenue against a common order covering 13 Bills of Entry was maintainable under Rule 6A of the CESTAT Procedure Rules, 1982.

Analysis: Rule 6A permits one memorandum of appeal where a common order covers multiple Bills of Entry, but the Explanation requires separate appeals where the impugned order-in-appeal relates to more than one order-in-original. Each Bill of Entry constituted an assessment order in itself, and the common appellate order disposed of separate appeals relating to 13 Bills of Entry. The Tribunal also followed the view that the number of appeals required corresponds to the number of Bills of Entry, and that monetary-limit considerations apply with reference to each individual appeal.

Conclusion: The single appeal filed by the Revenue was not maintainable, and the Revenue was required to file 13 separate appeals.

Final Conclusion: The Revenue's challenge failed on the preliminary objection, and the impugned appellate relief in favour of the importer remained undisturbed.

Ratio Decidendi: Where a common order-in-appeal disposes of separate assessment orders relating to multiple Bills of Entry, the appellant must file a separate appeal for each assessment order if the procedural rule so requires.

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