" 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.

Wednesday, 25 June 2025

No consultation with staffside for ongoing cadre restructuring of CBIC

 

ALL INDIA ASSOCIATION OF CENTRAL TAX

GAZETTED EXECUTIVE OFFICERS

(Earlier known as All India Association of Central Excise Gazetted Executive Officers)

President:                                             Address for communication:                                      Secretary General:

Kajal Kumar Mandal                         Flat No. 6, SE 11, Shastri Nagar, Ghaziabad                           Harpal Singh

Mob. 9957366172       mail Id:aiacegeo2019@gmail.com        Site:cengoindia.blogspot.in       Mob. 9717510598

Chief Patron: Ravi Malik Patrons: A. Venkatesh, C. S. Sharma, M. Nagaraju

Vice Presidents: B C Khatik, K D Venkatraman  (Central) Swapan Kr Das, Subrata Adhikary (East) Ashish Vajpayi, B B Sharma (North) G Srinivas Reddy, G Ananda Sukumar (South) Siddhraj Parmar, Vimal Kishore Soni (West) Joint Secretaries: Manoj Kumar, T J Manojumon (Central) Pradyut Purkayastha, Ashis Maji (East) Rajeev Prakash, Anil Sreedharan (West) Prabhakar Sharma, R B Sahu (North) K Yugandhar Kumar, S M Kosalaya Devi (South); Office Secretary: B C Gupta Treasurer: Manoj Kumar Liaison Secretary: Bhoopesh Organising Secretary: Utkarsh Sharma South Zone Coordinator: R Keny Legal Coordinator: S Sabarwal Joint Organising Secretary: Jayant Dey East Zone Coordinator: Debasish Modak

(Recognised vide F.No.B-12017/17/2022-AD-IV A dt. 14.07.23 of CBIC, Govt. of India)

Ref. No. 44/AIB/P/25                                                                       Dt. 24.06.25

To,

Sh. Arvind Shrivastava,

Revenue Secretary,

North Block, New Delhi.

Sub: No consultation with staffside for ongoing cadre restructuring of CBIC.

Sir,

            It is submitted with due regards that the service associations of stake holders were invited by DG, HRD, CBIC to make consultations on the cadre restructuring sometimes in 2018. But, as the Association came to know, the earlier proposal has been totally changed without making any consultation with the service associations of staffside. At the earlier time, the proposal was circulated among the staff associations before and after finalization but nothing such happened this time. During the process of cadre restructuring of 2013 also, the staff associations were duly consulted and the due meetings were held with them but the same is missing this time.

            2. This Association is totally in dark this time. Whatever we know, that is based on hearsay in the corridors of administration or some PPT being floated a few months ago on social media. We came to know that only non-recognised association of IRS officers has been, officially or unofficially, consulted but no opportunity of consultation has been given to the recognized associations of staffside. We came to know that many drastic things have been proposed in the cadre restructuring which are against the interest of stake holder staffside whereas many lucrative things have been proposed in the interest of the direct recruit IRS officers to enhance their promotional avenues better than even IAS.

            3. Because of every power being vested in the direct recruit IRS officers in CBIC, only their interest is being watched by the CBIC. The CBIC, actually, has become only for, by and of direct recruit IRS officers. They are worried only for the interest and promotional avenues of direct recruit IRS officers equating them with IAS. They have no worry about staffside, particularly executive officers who are retiring after getting one promotion to the post of Superintendent after being appointed as Inspector. The CBIC managed the things in such a manner in the last cadre restructuring that a young Assistant Commissioner (Level-10) became Commissioner (Level-16) within 17 years. They also don’t hesitate to get relaxations for direct recruit IRS officers from the nodal departments to promote them whereas no measure has been taken by them for executive officers of staffside to remove their stagnation despite of the recommendations of Cabinet during the last cadre restructuring to take measures to remove the stagnation of these executive officers independent of cadre restructuring.

            4. As your goodself knows that every state has only one Commissioner in State GST, thus there are total around 36 Commissioner throughout India in the State GST against more than 400 Commissioners in Central GST. But very surprisingly, they not only have many times more Commissioners in Central GST in comparison to the Commissioners in State GST but also have Principal Commissioners, Chief commissioners, Principal Chief Commissioners etc. etc. It is well pertinent to mention that no such post exists in the State GST because the actual GST work is limited only upto the post of Additional Commissioner. For example, a single state of Uttar Pradesh has 26 Commissioners in Central GST in comparison to only 1 Commissioner in State GST. Other larger states like Maharashtra etc. may be having more than 26 Commissioners in Central GST against one Commissioner in State GST. It is not understood why such huge number of Commissioners are required in Central GST despite of Act, rules and provisions of GST being same in Central GST and State GST in addition to the provisions of cross empowerment and also no GST work defined above the post of Additional Commissioner.

            5. Despite of above facts, they want to enhance the number of posts at each level for direct recruit IRS officers. The Association came to know a few months ago through PPT on social media that they proposed to enhance the posts of Principal Chief Commissioner from 14 to 40, Chief Commissioner from 38 to 50, Principal Commissioner from 99 to 138, Commissioner from 335 to 562 and Additional/Joint Commissioner from 932 to 1748 in the interest of direct recruit IRS officers. Thus, there would be 790 posts of Commissioners and above in Central GST against only 36 posts of Commissioners in State GST. Perhaps they want promotional avenues better than even IAS. Moreover, they have managed the posts of Deputy Commissioner in such a manner that their direct recruit Assistant Commissioners (100%) become Deputy Commissioner within four years of selection whereas they proposed only 22% promotional quota for the promotee Assistant Commissioners to become Deputy Commissioner which will take long years for them to be promoted or they will never be promoted to the post of Deputy Commissioner except a few on account of a separate service proposed by them in distorted manner for promotee Assistant Commissioners only upto the level of Deputy Commissioner which was earlier proposed upto the level of Commissioner.

            6. Not only it, they have also proposed to convert four years time scale (Level-9) given to the Group B executive officers (in the pay scale of Superintendent) after four years of service to an intermediary promotional post naming it as Senior Superintendent which was not proposed earlier due to the opposition by the Association. This will not only be against the Subramaniam verdict given by the Hon’ble Supreme court but also be against the CCS (Revised Pay) Rules, 2008 published under Article 309 of the Constitution. Being against the Subramaniam verdict, needless to submit that it will be direct contempt of the Hon’ble Supreme Court. Moreover, after making it a promotional post, it will be vacancy based and full procedure of DPC will be followed to fill-up these vacancies. Net result will be that our officers working in the pay scale of Superintendent on account of MACP upgradation will never get this benefit after 4 years of service. These posts being vacancy based, our Superintendents will also not be able to get the benefit of time scale or promotion after 4 years of service. Instead of proposing the merger of Level-9 (GP of 5400/- in PB2) and Level-10 (GP of 5400/- in PB3), they want to make the intermediary GP of 5400/- in PB2 a promotional post.

            7. They also have proposed to stop the direct recruitment of Inspector at Pay Level-7 whereas direct recruitment at Pay Level-7 will continue in other departments including the sister organization of CBDT. Thus, their intension is to give screwed structure to the organization of CBIC and degrade the cadre of Inspector instead of giving structural parity with State GST and CBDT.

8. It is very clear from above that they are interested to give all benefits to direct IRS officers only without taking care of other cadres of staffside. Rather they want to snatch benefits from other cadres as mentioned in para 6 and 7 above. Moreover, now VIIIth CPC has already been declared and we don’t know which pay scale will be merged and which posts will be curbed by the pay commission as ever. So, their proposal is no way justified or reasoned and seems to be prepared without application of mind.   

9. The Association came to know that a meeting of CBIC is fixed with your goodself in the end of this month. It is, therefore, requested that an appointment may kindly be given to us to enable making due submissions in person before your goodself prior to the meeting with CBIC. It is also requested that the copy of the proposal may kindly be provided to the Association before finalization and after finalization as done in the past.

Thanking you,

Yours sincerely,

                                                                                                                                                       

(HARPAL SINGH),

Secretary General.

Copy with the request for necessary action to:

(1)   The Cabinet Secretary, President House, New Delhi.

(2)   The Secretary, Department of Expenditure, North Block, New Delhi.

(3)   The Secretary, DOPT, North Block, New Delhi.