" 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.

Tuesday 20 September 2016

GST implementation

ALL INDIA ASSOCIATION OF CENTRAL EXCISE
GAZETTED EXECUTIVE OFFICERS
President:                                       Address for communication:                                     Secretary General:
R. Chandramouli                     240, Razapur, Ghaziabad-201001 (U.P.)                                        Ravi Malik
Mob. 08939955463 mail Id:ravimalik_sweet@yahoo.com, Site: cengoindia.blogspot.in    Mob. 09868816290
Vice Presidents: P. Parwani, L. L. Singhvi (Central); Anurag Chaudhary, Ravi Joshi (North); N. Raman, G. Srinath (South); B. K. Sinha, Ashwini Majhi (East); Rajesh Chaher, J. D. Patil (West) Joint Secretaries: Anand Kishore, J. S. Iyer (Central); R. K. Solanki, Ashish Vajpeyi (North); M. Nagaraju, Ajithkumar P. C. (South); P. K. Sen, S. Bhattachariya (East); Jasram Meena, M. K. Mishra (West) Office Secretary: C. S. SharmaTreasurer: N. R. Manda Liaison Secretary: A. S. Kundu Coordinator on Telangana: P. Shravan Kumar
(Recognised by G.O.I., Min. of Fin. vide letter F.No. B. 12017/10/2006-Ad.IV A Dt.21.01.08)
Ref. No. 153/AIB/G/16                                                                          Dt. 20.09.16
To,
Sh. Najib Shah,
Chairman, CBEC,
North Block, New Delhi.
Sub: Implementation of GST.
Sir,
               It is submitted with due regards that the Association is in total dark regarding structure under the GST which is already on cards to be implemented w.e.f. 01.04.17. No formal discussions have been held with any of the staff Associations including AIACEGEO by any of the authorities on GST. Staffside is in total dark regarding technical, infrastructural, human resource etc. aspects of GST.
               2. The resolution passed on GST by this Association in its AEC meeting is also enclosed herewith. A formal meeting with AIACEGEO is an urgent need of the time to discuss all aspects by the concerned authorities particularly keeping in view that the cadre of Central Excise Superintendent is going to play the key role under GST. Association expects that GST would boost the career prospects of group ‘B’ Central Excise executive officers who are forced to retire only after one promotion after joining the job of Inspector and already facing the worst career prospects under the Govt. of India. Nothing has been done till date to improve the career prospects of these officers despite of the recommendations of the Cabinet to bring some scheme for group ‘B’ officers of Central Excise to remove their stagnation independent of the cadre restructuring.
               3. In view of the above, it is requested to have an immediate meeting with the Association on the issue to discuss the points raised in the enclosed resolution as well as submitted above.
               Thanking you,
Yours faithfully,

Encl: As above.

(RAVI MALIK),
Secretary General.  
Copy with the request to hold the due meeting to-
1) Revenue Secretary, North Block, New Delhi.
2) The MOS, Finance (Revenue), Ministry of Finance, North Block, New Delhi.
3) The Finance Minister, Govt. of India, North Block, New Delhi.
4) The Prime Minister of India, South Block, New Delhi.




(RAVI MALIK)
RESOLUTION ADOPTED BY AIACEGEO IN THE AEC MEETING HELD ON 11th September, 2016 IN DELHI

TECHNICAL
1)    Assessment or Scrutiny responsibility should be distributed from Superintendent to Additional Commissioner level depending on the monetary limit and assessable value, number of assessees and number of credit documents. Inspector should be in the workflow in the ACES before the Returns / Registrations are verified / scrutinized by the Superintendent.

Justification

a)     Parity with State VAT & Income Tax in tax administration.
b)    To do away with Review mode of Tax assessment and instead adopt Revision mode.
c)     To minimize litigations and avoid revenue being locked up.
d)    To ensure Officer Orientation in finalizing higher volume of Tax.
e)    To ensure proper distribution of responsibility and accountability.

2)    The Assessment Structure should be 1:2:4 between JC/ADC : DC/AC : Supdt.

3)    Between Scrutiny and Appeals – Powers of Review should be delegated between AC, Jt / Addl Commissioner & Commissioner to help facilitate the Trade.

4)    In the Adjudication procedure any adjournment/ non-appearance by parties, the said period should be left outside the statutory three / five years time limit to write off demands as proposed under the model GST Laws.


Technology
1)    GSTN Platform - Presently the stake of the Private Organisations in GSTN is 51% Private and stake of Govt is 49% only (Central + State). GSTN should be fully under Govt control to ensure the data security is not compromised.

The custodian of the sensitive data of Crores of Assessees in the GSTN should rest with the Govt (Central + State).

2)    The present status / working of ACES leaves much to be desired. In spite of 7 years of implementation of ACES, not a single Report has been reduced by the Board for the field.

The Report Generation Module in ACES is very rudimentary as not many reports useful to the field formations is available. There are no up to the month report in CEX in ACES till date.

Further, there are no useful Service Tax Revenue Reports in ACES either based on the Returns or NSDL data.

Many a times lack of useful reports makes officers from the field formation to go to the assessees.

The EDW could have been useful if the access had not been limited to only few USERS per Commissionerate. The EDW access is not only useful for Statistical Information, but the wealth of information can be used by the Anti-evasion Wing of the Commissionerate. On this account our own data cannot be used effectively by the Deptt for plugging the Revenue Leakage.

It should be ensured that we do not carry the negative legacy of ACES in the GSTN era. The design of the reports should be such that it is self explanatory and ready to use and satisfies the need of the Ministry/ Board. It should eliminate the need for generating the Reports at Range Level. Many a times lack of useful reports makes officers from the field formation to go to the assessees.

3)    The access of ACES / GSTN Portal for the Officers should be made through Internet so as to enable the Officers at all levels to access the GSTN/ ACES System on 365 X 24 X 7.

This will not only increase the efficiency of the Deptt but also drastically reduce the recurring expenditure involved in getting the BSNL / MTNL MPLS leased Line or VPN o BB.

4)    Presently the access of 1 User of NSDL EASIEST provided to each Commissionerate is grossly inadequate. Again, the data belongs to the Deptt and the Officers are unable to use the data extensively as the access is restricted to only 1 User. 


Infrastructure

1)    Provision of Cadre Wise entitled working space with all necessary equipments like laptops, desktop PCs, Printers etc. in uniform manner throughout the country.

2)    Every Group B Officer of CBEC should be provided with a laptop and a 4G Data Card. Presently the benefit of 1% incremental revenue scheme has never percolated to Gr B Officers.

3)    The proposals for Residential and Official accommodation should be cleared by DGHRD and Board in a Time Bound manner.




HR Policies

1)    A long term notified HR Policy should be evolved for the entire Organisation in consultation with the Staff/ Officer Association. Any future Restructuring/ Re-organisation as a fall out of GST should be in consultation with all Staff Association.

2)    Structure of the Deptt should depend on the workload depending on number of Returns and documents to be scrutinized and in relation to declared duties and responsibilities of the Officers.

3)    Audit, Intelligence and Anti-evasion wings should be strengthened and well equipped.

4)    Well defined Training Mechanism. Training based on Model Law to be opposed. Full training should also be given after the Law / Rules come in to force.


 Since the GST Act, Rules and procedures are evolving, depending upon the situation insertions or modifications to the above proposals have also to be considered as a continuing process.