ALL INDIA ASSOCIATION OF CENTRAL
EXCISE
GAZETTED
EXECUTIVE OFFICERS
President:
Address for communication:
Secretary General:
A. Venkatesh 240, Razapur,
Ghaziabad-201001 (U.P.)
Ravi Malik
Vice Presidents: Apurba Roy, P. C. Jha (East); A. K. Meena,
Somnath Chakrabarty (west); Ashish Vajpayee, Ravi Joshi (North); B. Pavan K.
Reddy (South); K.V. Sriniwas, T. J. Manojuman (Central) Joint Secretaries: Ajay
Kumar, R. N. Mahapatra (East); B. S. Meena, Sanjeev Sahai (West); Harpal Singh,
Sanjay Srivastava (North); M. Nagraju, P. Sravan Kumar (South); Anand Kishore,
Ashutosh Nivsarkar (Central)
Office Secretary: C. S. Sharma Treasuer: N. R. Manda Organising
Secretary: Soumen
Bhattachariya
(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. 215/AIB/C/18
Dt. 10.08.18
To,
Sh. Balesh
Kumar,
ADG, HRM-I,
CBIC,
New Delhi.
Sub: Manpower and infra-structure requirement
under GST.
Sir,
Kindly refer to the meeting held on
01.08.18 on the cadre restructuring alongwith the Ref. No. 202/AIB/A/18 Dt.
29.07.18 and 204/AIB/A/18 Dt. 31.07.18 of the Association.
2. It is to
submit with due regards that the CBIC is already short of revenue under GST as
proportionately compared to State governments. No need to say that this is the
result of the shortage of working hands particularly at Group ‘A’ entry level
in proportion of workload. The Finance Secretary has also observed that the Central
officers are far behind the State officers under GST in giving the due results.
The observations made by the Finance Secretary are required to be analysed in
r/o manpower, workload per individual and infrastructure available to our
officers in comparison to the State officers to take due corrective measures
under the cadre restructuring or even independent of it.
3. Not only it, the issue is
also to be analysed from the angle of the job-satisfaction. No need to say that
the officers of the level of the Superintendents are very well job-satisfied in
the State GST in r/o of the pay matters, infrastructure, basic amenities and
entitled facilities including office space, office infrastructure, official vehicles
etc. etc. It is well pertinent to mention that they are not only working in the
pay scale equivalent to Level-10 (in comparison to Level-8 of our
Superintendents) but have also been re-designated/upgraded as Asstt.
Commissioner. They are also getting actual four upgradations under MACPS within
26 years of service (e.g., Uttar Pradesh Govt.) without offsetting with time
scale whereas our Superintendents are getting only two in 30 years with
offsetting with time scale. Thus, counterparts of our Superintendents in the state
governments are easily getting a pay scale of Level-13 in a short period whereas
our Superintendents are forced to retire merely at Level-10 even after a
service of 30 to 35 years. So, state officers have every reason to be job-satisfied
whereas, in contrary, our Superintendents/Inspectors have every reason to be
job-dissatisfied. No need to say that the job satisfaction is
related to results and job efficiency in direct proportion in any job.
4. Sh. B. B. Agarwal, the
Chief Commissioner of Hyderabad Zone, has made the interesting study on the
issue of manpower and infrastructure in comparison to State GST which has
already been submitted by him to the CBIC and also enclosed herewith as asked
by the administration during the meeting. No need to say that the study made by Sh. B. B. Agarwal is required
to be taken seriously in the cadre restructuring.
5. As on date, CBIC is having around 36 lac GST assesses (which will be
on regular increase with the passage of time). So, we require sufficient
manpower not only relating to GST field work for dealing with assessees but we
also require additional manpower relating to the work of the Headquarters
offices, Anti-evasion, Audit and Customs. We are having 1000 assesses per Range
Office as average. However, many Ranges are having even 8000-12000 or more
assesses as also accepted by the administration during the meeting. Such a high
number of assessees per Range Office is really terrible creating an unworkable
situation and putting unwarranted burden and mental tension on our
Superintendents who are already overburdened for the want of due helping hands
and being always busy in preparing various reports leaving no time for
scrutiny, assessment, show cause notices, adjudication orders etc. or any other
important work. The administration also accepted during the meeting that there
should be not more than 400 assessees per Range Office as per the GST modal. Due
number of helping hands are also required, if we expect smooth functioning at Range
level.
6. Likely, there should also not be more than 2000 assessees per Division
having five Range Offices alongwith sufficient manpower for smooth working. Thus,
we need at least 2000 Group ‘A’ entry level officers as on date only for the
Division offices which will be on regular increase with the passage of time in
the direct proportion of the increase
in the number
of assessees. No need to say that we need even more manpower
particularly at Group ‘A’ entry level for Headquarters offices, Anti-evasion
and Audit as well as sufficiently high manpower for Customs formations for
smooth tax administration. Accordingly, total number of Group ‘A’ entry level
officers comes out to be more than 7000 as per the rough assessment made by the
Association.
7. It is also worth to mention that the Range level offices in the state
governments having around 2000 assessees are manned by 14 to 20 officers
including executive, ministerial and executive staff. Thus, our Range Office
should also be manned by 5 persons at least.
8. Very interestingly, the Range level offices in the state governments
have also been provided with 2 to 3 vehicles (four wheelers) per office.
Accordingly, our Range Office should also be provided at least with one vehicle
(four wheeler).
9.
Now, we come to the demand of the IRS Officers Association to abolish 2118
temporary posts of Asstt. Commissioner. No need to say that these posts have
been created based on the functional requirement of the CBIC and can’t be
abolished on this count itself as also accepted by the administration during
the meeting of 01.08.18. Not only it, every post has again already been
justified from the angle of the functional requirement at the time of the GST
implementation. And as submitted above, the functional requirement will regularly
increase with the passage of time in the direct proportion of the increase in
the number of the assessees. Instead of abolition, these posts are required to
be upgraded as Deputy Commissioner meant for the promotion of our
Superintendents only and the total strength of Asstt. Commissioners as well as
Deputy commissioners (both posts being functionally same) is to be shown combinedly
as being shown for Joint Commissioner as well as Addl. Commissioner. No need to say that not only the Stagnation
Committee headed by your goodself has already recommended the promotion of the
Superintendent to a Senior Time Scale post but the same has also been
recommended by the CBIC vide OM F.
No.A-26017/154//2015-Ad.IIA Dt. 22.02.16. Accordingly, all promotee Asstt.
Commissioners may also kindly be upgraded as Deputy Commissioner and their
temporary service may also be counted for further promotions.
10.
However, the motive mentioned by the IRS Association behind the abolition of
temporary posts of Asstt. Commissioner was the placement of younger batches of
IRS officers at particular seats. So, they seem worried only about the
particular postings of their member officers instead of functional requirement
of CBIC. If the placement is the criterion, it is requested that the promotee Group
‘A’ officers should also be given equal opportunity of posting at particular
seats for due exposure in the interest of CBIC particularly keeping in view their
huge work experience.
11.
The IRS Officers Association has also suggested to designate the Superintendent
with 5/6 years of service as Senior Superintendent. We have already submitted
our views on this issue vide the letter Ref. No. 206/AIB/C/18 Dt. 06.08.18 of the Association
as asked by your goodself during the meeting. However, it is further submitted
that the post of Senior Superintendent was falling under the category of Group ‘A’
in the past with a pay scale equivalent to Level-10. Accordingly, the best
option is to designate our all Superintendents irrespective of length of service
as Asstt. Commissioner in the pay scale equivalent to Level-10 and further
promotion to Deputy Commissioner like State GST.
12. In view of
the above, the Association requests that due care may kindly be taken in the ensuing
cadre restructuring to create the sufficient posts at Group ‘A’ entry level
alongwith providing sufficient manpower at Superintendent, Inspector and lower
levels alongwith due infrastructure. The posts may also be created at higher
levels as per requirement keeping in strict view that these should not be less
than one third of the relevant feeder level as per govt. guidelines. These
guidelines may also be taken care for creating the posts at Group ‘A’ entry
level meant for the promotion of Group ‘B’ officers, i.e., the posts at Group ‘A’
entry level should not be created less than 1/3rd strength of the
strength of Group ‘B’ officers.
Thanking you,
Yours sincerely,
Encl: As above.
(RAVI MALIK),
Secretary General.
Copy with the
request for necessary action to:
The DG, HRD,
CBIC, New Delhi.
(RAVI MALIK)
