Separate appeals required for each Bill of Entry when a common order-in-appeal covers multiple independent assessments.

Where a common order-in-appeal covers multiple independent assessment orders, each Bill of Entry must be challenged by a separate appeal under Rule 6A of the CESTAT Procedure Rules, 1982. The Tribunal treated each Bill of Entry assessment as a distinct assessment order and held that the appeal requirement follows the number of such assessments, not aggregation across them. The Revenue's single appeal against seven Bills of Entry was therefore not maintainable, and separate appeals were required.

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Issues: Whether a single appeal by the Revenue was maintainable against a common order-in-appeal covering the assessment of seven Bills of Entry.

Analysis: Rule 6A of the CESTAT Procedure Rules, 1982 permits one appeal where multiple bills of entry are dealt with in a single common order-in-original, but the Explanation requires separate memoranda of appeal where the impugned order-in-appeal relates to more than one order-in-original. The assessment of each Bill of Entry is treated as a separate assessment order, and the appeal requirement is therefore linked to the number of such assessments. The Tribunal also followed the view that monetary-limit policy is to be tested appeal-wise and not by aggregating multiple appeals.

Conclusion: The single appeal filed by the Revenue was not maintainable, and separate appeals were required for the seven Bills of Entry.

Final Conclusion: The challenge to the enhanced assessments could not be entertained in a single appeal, so the Revenue was required to proceed by filing separate appeals for each Bill of Entry.

Ratio Decidendi: Where a common order-in-appeal covers multiple independent assessment orders, each assessment must be challenged by a separate appeal in accordance with Rule 6A of the CESTAT Procedure Rules, 1982.

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