" IRS OFFICERS PROMOTED FROM THE GRADE OF SUPERINTENDENT OF CENTRAL EXCISE ARE ALSO MEMBERS OF AIACEGEO. THIS IS THE ONLY ASSOCIATION FOR SUPERINTENDENTS OF CENTRAL EXCISE AND IRS OFFICERS PROMOTED FROM THE GRADE OF SUPERINTENDENT OF CENTRAL EXCISE THROUGH OUT THE COUNTRY . President Mr.T.Dass and SG Mr. Harpal Singh.

Thursday 5 May 2016

COC Memo

CO-ORDINATING COMMITTEE IN DEPARTMENT OF REVENUE
(Representing Staff/Officer Associations under CBEC & CBDT)
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F.No.CoC/CPC/2016-17                                                                                     Dated, 2nd May, 2016

To
The Hon’ble Minister of Finance,
Govt.of India,
North Block, New Delhi.

                                                Sub:  7th Central Pay Commission
Respected Sir,
      With humility and a desire to seek a way out of the bleak circumstances arising out of the recommendations of the 7th Central Pay Commission, it is submitted with due regards that the 7th CPC through its recommendations have disturbed certain existing horizontal relativities in the case of the following cadres in the Revenue Department even though there had been no susceptible change in the assigned duties and responsibilities of those cadres where higher pay levels were assigned.  We, therefore, seek to draw your kind attention to the grievances of the entire cross-section of Group C, Group B and promotee Group A officers of the Revenue Department as stated below in brief:
 

1.      Havildar/Sepoy of CBEC
            The Havildar & Head Havildar of Customs, Central Excise & Service Tax being the uniformed officers with proper training in arms operations and selected on scrutiny of physical standards are the base level executive force and face of the department. The parity with counterparts in CBI/IB was regularly demanded and even the Finance Ministry vide letter no. A-26011/7/94-Ad II (A)(PC) dated 23.08.1995 specifically detailed the correlation of job profiles of corresponding posts of CBEC and CBI. Despite all these attempts, the successive Pay Commissions failed to assess the duties and responsibilities of these Cadres and the justified demands remained unattended. Now, assigning the pay level corresponding to Grade Pay of Rs. 2000 after upgrading it from the present level of the Grade Pay of Rs. 1800 will bring long delayed justice to these Cadres.  

2.      Tax Assistants of CBDT/CBEC :
The 6th CPC had assigned the Tax Assistants in Revenue Department the Grade Pay of Rs 2400/- in PB-2. The Auditors and Accountants in IA& AD and other Accounting Organizations, viz Defence Accounts, Civil Accounts, Railway Accounts, Postal Accounts etc, were assigned the Grade Pay of Rs. 2800/-. The nomenclature for the present Tax Assistants was earlier UDC and for the same grade in Indian and Audit Department and other Accounting organizations are Accountants/Auditors.  Both the cadres, i.e., the UDC/Tax Assistants in Revenue Department and the Accountants/Auditors in IA & AD and other accounting organisations were in the same pay scale all along till the Government revised the pay scale of Accountants in 2003, i.e., during the period under which the 5th CPC pay scales were in operation.   The said order was an executive fiat of the Government of India.  It could be seen from the enclosed order that the demand of the Accounting Employees were considered and conceded by the Government to bring parity of pay scales between the Accounting organizations and the Cadres of the Central Secretariat.  However, when the orders were issued, the Auditors and Accountants were given a higher pay scale than even the UDCs in the Central Secretariat, thereby disturbing the horizontal relativity between the cadres in other Departments of the Government of India. The Pay Scales assigned by the successive Pay Commissions to the UDCs of various Government of India offices including the IA &AD were at par. Accordingly for the upgradation of the pay scale effected in 2003, the pay scales of the Tax  Assistants and the Accountants/Auditors would have remained identical and the same. Aggrieved by this unilateral decision of the Department of Expenditure, Ministry of Finance, the CoC took up the issue with the Government bilaterally and through the forum of the Departmental Council.  However, no decision was taken on the specious plea that the Government having set up the 6th CPC would not like to go into the matter but would refer the matter to the 6th CPC.  The 6th CPC did not go into the merit of the issue at all.  They simply assigned the replacement scales in the form of PB-2 and Grade pay of Rs. 2400 for Tax Assistant and the Grade Pay of Rs. 2800 for Accountant/Auditor.   The CoC has taken up the matter with the Government in the Departmental anomaly Committee where the matter was discussed twice.  However, the Anomaly Committee did not submit its final recommendation to the Government till the 7th CPC was set up.  As in the case of National Anomaly Committee, the Departmental Anomaly committee also remained only a discussion forum where decisions are dragged on.  Had the Government recorded disagreement in the Anomaly Committee meeting, the issue could have been got settled before the Arbitrator.    The doors of negotiation were shut for ever by not convening the meeting of the Departmental Council or the Anomaly Committee.  The CoC took up the matter before the 7th CPC but they did not concede the contention on the erroneous ground that no such parity had existed ever before.  The Tax Assistant in Revenue Department must, therefore, be assigned  the Level Pay suggested by the 7th CPC for GP of Rs. 2800.  

2 (ii). This apart, it must be mentioned that Auditor, Accountant and Tax Assistants are recruited through SSC on passing the same Graduate Level Examination. It can be seen that the recruitment qualification stipulated for all these cadres are one and the same. Having been recruited through the same agency and the through the same examination, these categories of employees are to be placed in the same scale of pay or grade pay or pay level.  Moreover, the Tax Assistant in Department of Revenue is required to qualify a stringent Computer Proficiency Test which is a need of the hour in keeping with the Govt. of India mission for digital India.  The 5th Central Pay Commission had enunciated this dictum while upgrading certain cadres in certain department.  Ever since, this has been followed by the Government. 

2 (iii). The JCM National Council Staff side while making their submissions taking this fact into account had suggested as a measure of delivering exercise to remove the scale of pay or level equivalent to the Grade Pay of Rs. 2400 and retain only the Level pay suggested in replacement of the Grade pay of Rs. 2800.   Had the Pay Commission acceded this suggestion as a general measure, the parity between the Auditors/Accountants and the Tax Assistants in Revenue Department and UDCs of other Central Govt. Departments, which was all along in existence, could have been maintained. 

3.      Inspector/Preventive Officer/Examiner of CBDT/CBEC:  
The Govt. disturbed the existing horizontal parity in the pay scales of Inspectors/Preventive Officers/Examiners of Revenue Deptt. with the Inspectors of CBI by enhancing the pay scale of Inspectors of CBI without recommendations of CPC and also without any increase in their responsibilities. Vth CPC brought above analogous posts at par but the Govt. again enhanced the pay scale of pay scale of CBI Inspector. On repeated representations, the Government issued orders bringing back the parity by placing the Inspectors/Preventive Officers/Examiners at par with Inspector of CBI/IB.  A scrutiny of the relevant files of the Department of Expenditure will reveal the crux of the issue that came up for the consideration of the Government which resulted in the issuance of the orders.   The 6th CPC in the process of delayering the pay scales merged the pay scales of 5000-8000, 5500-9000 and 6500-10500 and assigned the Grade pay for all at Rs. 4200.  Again the issue was taken up with the Government and the matter could be later set right whereby the Government assigned the Grade pay of Rs. 4600 to the Inspectors/Preventive Officers on par with the Inspectors of CBI and similar cadre in the IB.

3 (ii). We had made submissions before the 7th CPC to assign higher pay scale for the Inspectors/Preventive Officers/Examiner at par with the Assistant Accounts officers of the IA& AD Department.  The Assistant Accounts officers were once having the designation of Section officers and were in a slightly higher pay scale than that of the Inspectors/Preventive Officers/Examiners.  The assigning of higher pay scale for Section officers by the 3rd CPC and denying similar upgradation for the Inspectors was the subject matter of discussions in the Departmental Council of the Ministry of Finance.  However, the Government did not accede to this demand in the council. Having recorded disagreement at the Council, the issue went to arbitration.  The Board of Arbitration taking into account all relevant facts came to the conclusion that the Inspectors Pay Scales has to be revised on the grounds of their duties and responsibilities.  It assigned them the pay scale of Rs. 500-900 where as the Section officers were in the pay scale of Rs. 550-900.  The fact remained that complete parity was not immediately given which became a reality only when the 4th CPC as a process of delayering upgraded the pay scale of 500-900 into 550-900.  The IA & AD Department went in for a complete cadre restructuring later and they changed the nomenclature assigned to various cadres in that Department and the Section officers became the Assistant Accounts officers.  In 2003, the Government of India conceding the demand of the IA & AD and the employees of other Accounting organizations brought parity in the pay scales of the cadres of the Accounting organizations and the Central Secretariat.  The observation of Pay Commission that there had been no parity between the Asst. Accounts officers and Inspectors/Preventive Officers at any point of time was therefore not based on fact. 

3 (iii). Our demand before the Empowered Committee of Secretaries is to bring the parity in pay scales of Inspectors/Preventive Officers/Examiners with the Inspectors of CBI and similar cadre of IB as that was all along in existence right from the inception.  The responsibilities and duties of IB or CBI had not undergone any change between 2006 and 2016 which alone would have justified the decision of the 7th CPC to provide higher pay scales to the Inspectors of CBI and IB.  As mentioned earlier, the Government has assessed the duties and responsibilities assigned to the Inspectors of both CBI, IB and Revenue Deptt. on the same footing not once but twice.  Therefore, the assigning higher pay scale to Inspectors of CBI but denying the same to the Inspectors/Preventive Officers/Examiners of Revenue Deptt. is totally unjustified and must be characterized a subjective decision without appreciation of all relevant facts. The approach of the 7th CPC while going through the pay matters in respect of Inspectors of CBEC & CBDT was such a casual one that they went on record at para 11.18.60 of the report that 6th pay commission assigned the Grade pay of Rs. 4200 to the CBEC/CBDT Inspectors and that of Rs. 4600 to CBI Inspectors which were respectively upgraded to Rs. 4600 and Rs. 4800 by the executive orders. In the same report at para 11.35.20, they proposed the upgradation of the pay of Inspectors of CBI & IB from Grade Pay of 4600 to 4800 which makes the report self contradictory. Even for our sheer dismay, they went on record that there was no parity in the pay structure of the Inspectors of CBEC & CBDT with that of CBI by totally ignoring the series of Judicial  as well as executive orders which restored the parity whenever it was disturbed.

3 (iv). Since the 7th CPC has assigned the pay level equivalent to the Grade pay of Rs. 4800 to the Inspectors of CBI and IB (similar Cadre),  the Inspectors/Preventive Officers/Examiners of Revenue Deptt. have to be placed in the same replacement  pay level of  Grade pay of Rs. 4800.  

4. Administrative Officer & Private Secretary of CBDT/CBEC
In the submissions of the CoC, one demand was very much in common, that is, common pay scale for all Group B Gazetted officers. This is for the first time that any CPC has even not bothered to mention this common cadre in its report (that means only replacement scale of PB-2 GP 4600 for our AO-PS cadres). It will be appreciated that this “Common Cadre” tag has so far been instrumental against these cadres in Revenue Department. But such is the misfortune that when the matter of pay comes, there is nothing common across the Departments. In our submissions, we pointed out the pay scales of CSS & CSSSS and various other Departments. We also pointed out that AO Grade-III cadre in Railways had successfully won the case upto the Hon’ble Supreme Court for the claim of PB-2 in GP of Rs.4800 but none has taken note of the development for implementing the same in Revenue Department.

4 (ii). The  Admn. Officers Grade III and Pvt. Secretaries are the common category officers in the Revenue Department. They had been assigned similar pay scale in all Departments across the Government. Taking into account the fact that they are to shoulder responsibilities and duties of Group B officers in Govt. service, they must be uniformly assigned with the replacement pay level suggested by the 7th CPC for Grade Pay of Rs. 5400/- in PB-2.

5.      Income Tax Officer /Superintendent/Appraiser of CBDT/CBEC
The Income Tax Officers/Superintendents/Appraisers are the executive officers and analogous to the DSP of CBI & DCIO of IB. They are the immediate supervisory officers for Revenue Department. The Inspectors/Preventive Officers/Examiners are to report to the Income Tax Officers (ITO)/Superintendents/Appraisers on all matters and especially on the specific executive functions entrusted to them. ITOs/Superintendents/Appraisers are assigned the status of a Group B Gazetted Officer in the Department and are entrusted with various functions including assessment and adjudication.

5 (ii). An ITO/Superintendent/Appraiser has the largest spectrum of job profile under his belt across all counterparts in Central Government. An ITO/Superintendent/Appraiser as an assessing officer acts as a quasi-judicial authority (undertaking the work of a judicial officer or a judge), an investigator as well as law enforcing officer (undertaking the work of a Police Officer), a Pleader as well as Solicitor (discharging the duty of a law officer in Govt. of India), an Accountant as well as an Auditor(performing the duty of an officer of Audit & Accounts Service), a Service Provider to Tax Payers (parallel may be drawn to job profile of the officers of any Social Sector Service providing Department) and last but not the least an Administrator (heading an independent office). The ITOs/Superintendents/Appraisers discharge most complicated and widest range of duties (including the most precious job of decision making) deserving the best across all counterparts.
5 (iii). Unfortunately, Pay Commission did certain routine parity analysis and rejected their claim summarily. Pay Commission has clearly failed to apprise that the parity with the officers of IA&AD had been restored by either the High Power Committee or Department of Expenditure and they are no lesser/inferior authority to Pay Commission being a recommending authority, so far as implementation of revision of pay scale is concerned. The audit and account work is the integral part of the job responsibilities of the Superintendents/Appraisers/ITOs. They head the audit teams just like Senior Audit/Accounts Officer. The Gupta Narain Committee recommended to place all the Group ‘B’ officers of the Central Government including Audit and Accounts Officers in a uniform pay scale of Rs. 2200-4000/- (Page–1343, para 83.85 of V CPC report). Govt. created the grade of Senior Audit/Accounts Officers to the extent of 80% of the then strength of the Audit/Accounts Officers in the scale of Rs. 2200-4000/- (made Rs. 8000-13500/- after Vth CPC) vide Order F.No. 6(82)-IC/91 Dt. 22.9.92. A grade pay of Rs. 5400/- in PB2 was recommended by the VIth CPC for Senior Audit/Accounts Officers (counterparts of Superintendents/Appraisers/ITOs) but they were placed in a grade pay of Rs. 5400/- in PB3 by the govt. without recommendations of CPC. Later, a grade pay of Rs. 5400/- in PB2 was also approved for the Central Excise Superintendents by the competent authority in Expenditure but the lower authorities of Expenditure returned the file with the view to send their case to the VIIth CPC vide UO No. 6/37/98-IC Dt. 24.11.14. Thus, Central Excise Superintendents etc. have been facing the hostile discrimination since very long as their counterparts of CBI, IB, Audit & Accounts etc. have already been placed in the higher pay scales by one way or other.  The IVth CPC recommended the same pay scale for Senior Auditors and Assistants in CSS, i.e., Rs. 1400-2600/- and Rs. 1640-2900/- for Central Excise Inspector on the basis of merit. It further recommended restoration of the ‘broad parity that existed between audit and accounts’. Govt. of India accepted this recommendation and extended the same pay scale of Rs. 1400-2600/- for Accounts staff of IA&AD and organised Accounts including Senior Accountants (80%) and Rs. 1640-2900/- for Assistant Accounts Officers (20%). The Audit/Accounts Officer was placed in the scale of Rs. 2000-3500/- (equivalent to Rs. 6500-10500/- of Central Excise Inspector) and Senior Audit/Accounts Officer in Rs. 2375-3500/- lower than Rs. 2500-4000/- as recommended by HPC and granted by the govt. to Superintendents/Appraisers/ITOs. Later, Senior Audit/Accounts Officer were placed in a scale of Rs. 8000-13500/- but Superintendents/Appraisers/ITOs in CBEC and CBDT were granted only a scale of Rs. 7500-12000/-. The VIth CPC recommended a grade pay of Rs. 4800/- in PB2 for Audit/Accounts Officer and a grade pay of Rs. 5400/- in PB2 for Senior Audit/Accounts Officer who were placed in the grade pay of Rs. 5400/- in PB2 and Rs. 5400/- in PB3 respectively by the govt. against the recommendations of CPC. It is also worth to mention that Superintendent/Appraiser/ITO and Senior Audit/Accounts Officer both are supervisory posts. As far as work responsibilities and duties are concerned, Superintendents/Appraisers/ITOs have to work in odd night duty hours also whereas Senior Audit/Accounts Officer works in the general duty hours of day only. Superintendents/Appraisers/ITOs have to combat with hard core criminals, white collard criminals and dreaded smugglers taking every risk on property and life of them & family but no such element is involved in the duties of Senior Audit/Accounts Officers. Superintendents etc. are also empowered to record the statement of criminals like a Magistrate having validity even before the Supreme Court but no such work responsibilities are conferred upon the Senior Audit/Accounts Officers. Quasi-judicial responsibilities to adjudicate the legal/judicial cases are also conferred upon the Superintendents etc. but no such work is performed by the Senior Audit/Accounts Officers. Section Officer (Non Gazetted) was in the pay scale of Rs.425-800/- in the Indian Audit and Accounts Department. 80% of the total posts of Section Officer were redesignated as Assistant Audit Officer in the higher pay scale of Rs.650-1040/- w.e.f. 01.04.84. After IVth CPC, these posts were placed in the pay scale of Rs.1640-2900 and Rs. 2000-3200/- respectively. They were placed in the pay scale of Rs. 5500-9000/- and Rs.6500-10500/- respectively after Vth CPC. These two posts have been merged and placed under the Grade Pay of Rs. 4800 in PB2 on the basis of VIth CPC recommendations. Likewise with effect from 01.04.92, 80% of the posts of Audit/Accounts Officer were placed in the higher pay scale of  Rs. 2200-4000/- with a benefit of fixation of pay on notional basis w.e.f. 01.04.87. The post was designated as Senior Audit Officer. In addition to audit and accounts work, Superintendents etc. are also supposed to do the work of investigation & intelligence, narcotics control, prevention of smuggling etc. New higher responsibilities of judicial and technical nature have also been conferred upon Superintendents etc. vide Circular No.  922/12/ 2010-CX issued vide F. No. 208/2/2009-CX-6 Dt. 18.05.10 and 130/12/2010–ST issued vide F. No. 137/68/2010-CX. 4 Dt. 20.05.10 by making due amendments in relevant Act very well after implementation of 6th CPC report. They have also been conferred with new higher technical/scientific responsibilities of ACES since 2010 very well after the implementation of 6th CPC report.  They are also conferred with the new additional responsibilities every year in the Finance Bill (Budget). Unfortunately, the CPC kept mum on all of the above facts. Despite of the admission by the Govt. under RTI vide letter No. 1148/Dir(A)/2008 Dt. 08.12.08 of Expenditure Department that the pay scale of Central Excise Superintendent etc. was enhanced to grant them parity with DSP of CBI/DCIO of IB, Central Excise Superintendent etc. were not given the said parity and were granted merely a lower pay scale of Rs. 7500-12000/- instead of Rs. 8000-13500/- or equivalent. Govt. enhanced pay scale of DSP of CBI considering them as Police Organisation while Hon’ble CAT as well as Vth CPC didn’t agree to consider CBI as Police Organisation. However, Special Police Establishment (Executive Staff) Recruitment Rules and CBI Recruitment Rules, 1987 consider department of Central Excise as a Police Organisation. Section 21 of Central Excise Act and Section 53 of NDPS Act confer powers of Officer-in-­Charge of Police Station on Central Excise officers. Not only it, the Central Excise personnel are also deployed on International borders, International Airports and International Sea Ports. These personnel have suffered heavy casualties while dealing with trans-border criminals and countering with dreaded smugglers. In fact in J & K, North Eastern states and other border areas of India, Central Excise personnel are deployed side by side with Army, BSF, CRPF and ITBP on the same location.  Also as per the OM issued vide F. No. 8/B/90/HRD (HRM)/2011 (Part-I)/4853 Dt. 21.10.14 and No.C.30013/11/2011-Ad.IV.A Dt.02.08.13 of the Govt. of India, the Central Excise Superintendents perform their duties in the nature and style of ‘Military’ and ‘Navy’ being uniformed officers bearing “Ashoka Emblem”. But again unfortunately, CPC paid no heed to the above facts. Central Excise Inspectors, Income Tax Inspectors, Preventive Officers and Examiners get a benefit of mere Rs. 200/- on being promoted to the a PB2 post whereas analogous Inspectors  of CBI/IB are being promoted to a PB3 post with a benefit of Rs. 800/-.         Analogous posts of Inspectors (feeder posts) of Central Excise, CBI/IB, Income Tax, Preventive Officers and Examiners have already been placed at par in a grade pay of Rs. 4600/- but the analogous promotional posts, i.e., Central Excise Superintendent, Income Tax Officer, Customs Superintendent and Appraiser (GP-Rs. 4800/-) and Deputy Superintendent of CBI/DCIO of IB (GP-Rs. 5400/- in PB3) are yet to be placed at par. Till 7.2.1996, the pay scale of both promotional posts (Central Excise Superintendent, Income Tax Officer, Customs Superintendent, Appraiser and DSP of CBI) was same, i.e., Rs. 2000-3500/-. However, the Govt. of India vide DOPT OM No. 245/23/95 – AVD-II dated 08.02.1996  enhanced the pay scale of DSP of CBI to Rs. 2200-4000/- retrospectively w.e.f. 01.01.1986 without recommendations of CPC and also without any increase in their responsibilities. Now, it is gross injustice not to bring the promotional posts  at par particularly when the govt. also admitted that pay scale of Central Excise Superintendent, Income Tax Officer, Customs Superintendent and Appraiser was enhanced to Rs. 7500-12000/- to grant them parity with the DSP of CBI/DCIO of IB. Hence, promotional posts also being analogous, may also kindly be placed under equal pay scale to undo the disparity by placing Central Excise Superintendent, Income Tax Officer, Customs Superintendent and Appraiser in a pay scale equivalent to a grade pay of Rs. 5400/- in PB3 at par with DSP of CBI and DCIO of IB. It is also worth to submit again that the Expenditure Department had already agreed principally to grant a grade pay of Rs. 5400/- in PB2 vide UO No. 6/37/98-IC Dt. 24.11.14 to Central Excise Superintendent in consonance of the para 7.15.24 of the report of 6th CPC but not implemented on the pretext of the setting up of the 7th CPC. So, there is no rationale to place Central Excise Superintendent, Income Tax Officer, Customs Superintendent and Appraiser merely under a grade pay of rs. 4800/- or equivalent. The plea by above gazetted officers of Revenue Department for grant of GP of Rs. 5400/- in PB3 has been turned down stating that it is group ‘A’ entry scale. That being the case, how could group ‘C’ post of Inspector of CBI be upgraded to GP of Rs. 4800/- keeping several group ‘B’ gazettted cadres in GP of Rs. 4600/- and 4800/-. Moreover once upon a time, the feeder post of Assistant and promotional post of Section Officer were placed in the same pay scale in CSS. Likewise, feeder and promotional posts were being placed in the same pay scale in Audit and Accounts services. Group ‘B’ officers in Sates and Group ‘A’ All India Service Officers are also recruited in the same grade pay of Rs. 5400/- in PB3 and get next promotion to same post in grade pay of Rs. 6600/-. Accordingly, there should not be any problem to place the Superintendent etc. in the Grade Pay of Rs. 5400/- in PB3. This problem may, however, also be solved by promoting the Superintendent/Appraiser/ITO directly to STS post like many other counterparts or even making the group ‘A’ entry at Level 11 (equivalent to GP of Rs. 6600/-). The CBEC has also already recommended for the grant of a Grade Pay of Rs. 5400/- in PB3 for Central Excise Superintendents to Revenue Hqrs and also to give them next promotion in STS post vide OM F. No. A-26017/154/2015-Ad.IIA Dt. 22.02.16.
5 (iv). In view of the above, it is requested to undo the discrimination meted out to the Superintendents/Appraisers/ITOs by granting them parity with the counterparts like Senior Audit/Accounts Officers, DSP of CBI, DCIO of IB etc. by assigning the level pay equivalent to the Grade pay of Rs. 5400 in PB-3 and the consequent non functional grade equivalent to Grade pay of Rs. 6600 on completion of four year of service.
5 (v). Moreover, Pay Commissions always worked to merge the pay scales. The creation of Grade Pay of Rs. 5400/- in PB2 and PB3 by 6th CPC was illogical, unjustified and a gross mistake. This led to discrimination, resentment and consequential litigations. It was expected that this CPC would remove this disparity by merger of this bifurcation of single grade pay but, very unfortunately, the CPC has retained the same as Level 9 and Level 10. The same is, therefore, requested to be merged at Level 10. Merger of Level 9 and 10 has also been recommended by the CBEC to the Revenue Hqrs vide OM F. No. A-26017/154/2015-Ad.IIA Dt. 22.02.16.
5 (vi). The special allowances/risk allowance as available to CBI, IB, Police etc. are also required to be granted at least @ 25% of salary per month to the revenue/tax officers alongwith 13 months salary in the year and other perks/benefits. It is also worth to submit that the enforcement, investigation & intelligence is the integral part of the duties of the Revenue Officers like Police, CBI & IB. The counterparts of Enforcement Directorate have also been granted special allowance @ 25% of salary per month by the Govt. vide F.No. 16/5/2007.Ad.ED Dt.24.11.15 in our own Department of Revenue vide without recommendations of CPC. The executive officers of Customs are presently paid ‘Rummaging Allowance’ merely @ Rs. 500 per month for rummaging and intelligence work and all executive officers of revenue Department are required to work beyond office hours.
5 (vii). The most of group ‘B’ gazetted officers in Central as well as State governments are being promoted directly to a Senior Time Scale (STS) post with GP of Rs. 6600/- in PB-3 including CSS, CPWD, Railway Board, CSSS, AFHQ, CVC, UPSC, MEA, MPA, NCB, Rajya Sabha Secretariat, Enforcement Directorate in Revenue Department itself, Forest services, Police services, Foreign Services, Engineering services, State services etc., whereas Revenue Officers are being promoted merely to a Junior Time Scale (JTS) post with Grade Pay of Rs. 5400/- in PB-3. So, it is requested that the Revenue Officers may also kindly be promoted directly to a STS post. They may further be promoted to the post having the grade pay of Rs. 8700/- (like CPWD where group ‘A’ direct entry is also in a GP of Rs. 5400/- in PB3 like CBEC and CBDT) from STS post. It is also worth to submit that the posts in GP of Rs. 5400/- & 6600/- and Rs. 7600/- & 8700/- are functionally same. This point of promotion to STS was also appreciated and agreed by the Pay Commission in Mumbai hearing but not recommended. Direct promotion to STS has also been recommended by CBEC to the Revenue Hqrs. vide OM F. No. A-26017/154/2015-Ad.IIA Dt. 22.02.16.
5 (viii). The promotional hierarchy is varying department to department in the Central Govt. as under-
a) Somewhere Group ‘B’ Gazetted Officers are promoted to a Grade Pay of Rs. 5400/- in PB3 (CBEC, CBDT, Department of Posts etc.) whereas they are being promoted to a Grade Pay of Rs. 6600/- at other places (CSS, Railway Board, CSSS, CPWD, AFHQ, CVC, UPSC, MEA, MPA, NCB, Rajya Sabha Secretariat etc.).
b) Somewhere Group ‘B’ Non-Gazetted Officers are promoted to a Grade Pay of Rs. 5400/- in PB3 (CBI, IB, Hindi departments etc.) whereas they are being promoted to a Grade Pay of Rs. 4800/- or Rs. 4600/- at other places (CBEC, CBDT, Department of Posts, CPWD etc.).
c) Somewhere promotional hierarchy is 4600à6600à8700 (CPWD etc.).
d) Somewhere promotional hierarchy is 4600à4800à6600à7600à8700 (CSS, Railway Board, CSSS, AFHQ, CVC, UPSC, MEA, MPA, NCB, Rajya Sabha Secretariat etc.).
e) Somewhere promotional hierarchy is 4600à5400à6600à7600à8700 (CBI, IB, Hindi departments etc.).
f) Somewhere promotional hierarchy is 4600à4800à5400à6600à7600à8700 (CBEC, CBDT, Department of Posts etc.).
5 (ix). So, promotional hierarchy after entry into group ‘B’ may kindly be made uniform for the sake of justice to all. Posts under grade pays of Rs. 5400/- & 6600/- and also Rs. 7600/- & 8700/- being functionally same, ideal promotional hierarchy for all after entry into Group ‘B’ may only kindly be “4600à6600à8700à10000” on the pattern of CPWD. Officer may kindly be promoted, functionally or non-functionally, after the completion of residency period as prescribed by DOPT vide OM No. AB. 14017/61/2008-Estt. (RR) Dt. 24.03.09. It is 7 years for 4600/- to 6600/- and 10 years for 6600/- to 8700/- and further 3 years for 8700/- to 10000/- and so on. This point of uniform promotional hierarchy was also appreciated and agreed by the Pay Commission in Mumbai hearing but not recommended. The CBEC has also recommended to Revenue Hqrs for the uniform promotional hierarchy across all the Departments/Ministries under the Govt. of India vide OM F. No. A-26017/154/2015-Ad.IIA Dt. 22.02.16.
5 (x). BATCH TO BATCH NON FUNCTIONAL FINANCIAL UPGRADATION TO EXECUTIVE OFFICERS OF CBEC AND CBDT AT PAR WITH THE BEST PLACED COUNTERPARTS AFTER ENTRY INTO GROUP ‘B’ NON-GAZETTED OR EQUIVALENT GRADE: All organised group ‘A’ officers recruited with IAS,  best placed group ‘A’ service, in same pay scale through common entry have been granted financial parity with  counterparts of IAS in the form of non-functional financial up-gradation vide DOPT OM No. AB.14017/64/2008-Estt.(RR) dt.24.04.09 to compensate lack of promotions as compared to IAS. This scheme was introduced for group ‘A’ officers to compensate financial loss in comparison to counterparts of IAS. Thus, Revenue Officers may also kindly be granted non-functional financial up-gradation at par with their best placed common entry counterparts like CSS etc. (recruited in same pay scale through common entry examination) after entry into Group ‘B’ or equivalent grade. This NFU was also recommended to the Pay Commission by the department vide F. No. 8/B/70/HRD (HRM)/2014 Dt. 16.01.14 but, unfortunately, they kept mum on the issue despite of being agreed in Jodhpur meeting. It has again been recommended by CBEC to the Revenue Hqrs for our officers vide OM F. No. A-26017/154/2015-Ad.IIA Dt. 22.02.16.
5 (xi). Diet Allowance: The Pay Commission appears to have not taken note of the Diet Allowance being paid to the Air Customs Officers and Air Customs Superintendents working on International airports & likewise places and has dealt with the issue with regard to the Immigration Officers only. Our officers are being paid a meagre amount of Rs. 200/- per month towards compensation for food which by no way is anywhere near the actual expenditure being incurred by them. Diet Allowance, therefore, may kindly be granted as percentage of the Pay. It is also worth to mention that these officers work for 12 hours in a stretch without any lunch hour at these places.
1.      Equal Pay and Cadre Structure in the Administrative Wing :
Successive Pay Commissions have been making recommendations for equal Pay for similarly placed ministerial officers in Hdqrs. Organisation and Field formation.  The recommendation of 7th Central Pay Commission vide Para 7.1.4 (j) is worth mentioning here and reproduced below:
“The Commission accordingly strongly recommends parity in pay between the field staff and headquarter staff up to the rank of Assistants on two grounds firstly the field staffs are recruited through the same examination and they follow the same rigour as the Assistants of CSS and secondly there is no difference in the nature of functions discharged by both. …………..……”

6 (ii). There is a wide disparity of Cadre structure in the administrative wing between CBDT & CBEC and that with Hdqrs. Organisation.  These may be removed to improve efficiency at the cutting age level where policies of Govt. of India actually implemented.  Accordingly, we demand an identical Cadre structure of the administrative wing and a Pay structure both in CBDT & CBEC which will also place us on an identical structure of Hdqrs. organization i.e. Secretariat Offices.

2.      To finalise the Recruitment Rules as per suggestions of Recognised Federations/Associations immediately:  
After the Cadre Restructuring of both the Departments, new Recruitment Rules not yet finalised/notified except some Group C cadres. The RRs may be finalised/notified immediately after due discussions with the staff Associations/Federations.
 We would remain ever-grateful, if the above-mentioned issues are resolved by your kind intervention. We hope that your kind intervention will definitely bring a ray of hope for the entire cross-section of staffs and officers of the Revenue Department.

Thanking you,

                                                            Yours sincerely,
                                                                   
(RAVI MALIK)                               (ANUPAM NEERAJ)                   (RUPAK SARKAR)
                                                           
                                                             Joint Convenors
           
Copy to :
1.      The Hon’ble Minister of State, Finance, North Block, New Delhi.
2.      The Hon’ble Revenue Secretary, Ministry of Finance, North Block, New Delhi.
3.      The Hon’ble Chairman, Central Board of Excise & Customs, North Block, New Delhi.
4.      The Hon’ble Chairman, Central Board of Direct Taxes, North Block, New Delhi.