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Issues: Whether a single appeal was maintainable against one adjudication order disposing of multiple show cause notices, and whether difficulty in apportioning the consolidated penalty justified filing only one appeal.
Analysis: The Tribunal held that each show cause notice culminates in a separate order or decision for the purpose of appeal, even if the adjudicating authority chooses to dispose of several notices by one composite order. The existence of a common order does not alter the underlying character of the individual decisions on each notice. Reliance was placed on the view that as many appeals are required as the number of show cause notices decided by the order. The Tribunal also held that the inability to apportion the penalty in the appeal memo was not a valid obstacle, because the appellant could make that difficulty known in the form and seek appropriate directions from the Tribunal.
Conclusion: A single appeal was not maintainable; separate appeals equal to the number of show cause notices had to be filed, and the plea based on non-apportionment of penalty was rejected.