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 West 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/C/26
Dt. 24.06.26
To,
The DG,
HRD, HRM-I,
CBIC, New
Delhi.
Sub: Cadre Restructuring exercise in CBIC.
Madam,
Kindly
refer to the meeting held with your goodself on 15.06.26 and the selective
presentation of the cadre restructuring proposal made to the Association on
16.06.26. Kindly also refer to the Ref. No. 37/AIB/C/26 Dt. 08.06.26 of the Association.
2.
It is submitted with due regards that the main points presented to the
Association were as below-
(A) Direct
recruitment of Inspector Grade II at Level 6 instead of Level 7. The
Association is not in favour of such proposal because the pay scale and service
conditions proposed for Inspector Grade II will not be at par with the
Inspectors in comparable departments. Such a disparity shall adversely affect the
morale of the officers and undermine the attractiveness of the cadre further
affecting the work adversely. However, we were promised that 80% direct
recruitment would be in Level 6 and 20% in Level 7. The ratio of Inspector to
Superintendent has been shown 1:1 in the proposal which requires to be made at
least 3:1 alongwith additional Executive Assistants for smooth functioning. The
substantial gap between the sanctioned strength and the actual working strength
of Inspectors and Superintendents requires a more comprehensive review.
(B) Qualifying
service for promotion of Inspector to Superintendent to be 4 years instead of 2
years whereas it is prescribed to be 2 years as per DOPT guidelines. The
Association is also not in favour of enhancement of this residency period. It
should noway deviate the DOPT guidelines, otherwise officers will feel totally demotivated
affecting the work adversely in turn. The Inspector and Superintendent cadres
constitute the operational backbone of CBIC entrusted with the execution of
core departmental functions. Therefore, any restructuring exercise should
ensure that these officers receive adequate opportunities for career
advancement upto the highest levels commensurate with their responsibilities
and contributions.
(C) To abolish
automatic 4 years time scale (NFS) to be given to the Group B executive
officers after completion of 4 years of service. We were presented that it
would be made promotional post with designation of Senior Superintendent at
Level 9 after 4 years of service as Superintendent. It means that it would be
vacancy based and DPC would be conducted for the said promotion. In nutshell,
it projects that service would start at Level 6 and will get 3 promotions upto
Level 9. It is not known whether officers will go beyond it or not. So, as per
the presentation, no automatic time scale after 4 years of service will be
given to our officers in future. The Association is in total disagreement to
such proposal. However, we were promised that the post of Senior Superintendent
would not be created and 4 years time scale would continue.
(D) The proposal
seemed Direct Group A centric. Commissioner & above posts will be around
800 despite there being no work under GST beyond Addl. Commissioner. We don’t understand
how so many posts of Commissioner & above would be justified before the
nodal departments and Cabinet because merely a single Commissioner is looking
after the work under State GST in a State Govt. We appreciate the Govt.
objective of ensuring optimum utilisation of resources and promoting
administrative efficiency. In this context, it may be considered whether
vacancies in posts that involve limited operational responsibilities or have
become redundant due to changes in work processes could be rationalised, while
simultaneously strengthening field formations where manpower shortage directly
affects departmental performance. Actual need is to enhance the strength at
lower and middle executive levels for smooth and revenue friendly functioning.
(E) Separate
service for promotee officers from Asstt. Commissioner to Deputy Commissioner
with qualifying service of 5 years for promotion (Not known when DPC will
happen) instead of 4 years which is for Direct Recruit Asstt. Commissioners.
Promotional quota of 22% from promotee Asstt. Commissioner to Deputy Commissioner
was presented whereas Direct Recruit Asstt. Commissioners will keep promoted as
Deputy Commissioner within 4 years based on vacancy year on 100% basis. This
seems totally discriminative. Moreover, in earlier proposal, this separate service
was upto the level of Commissioner which requires to be reinstated with
sufficient number of posts at each & every level.
(F) Merger of 3
Group B executive cadres into one and maintenance of All India Seniority List.
It seems a good proposal which should have been done decades ago. The
Association requested for it since very beginning but nothing happened. It may,
however, be done independent of cadre restructuring.
(G) Manpower enhancement
in GST by 38% and in Customs by 84%. The manpower enhancement for GST is too
less. It should be enhanced multifold with due infrastructure based on State
GST model. In the most of the States, SGST manpower has been provided in
sufficient number with due infrastructure and division of various works
including assessment, scrutiny etc. upto the highest level.
(H) Number of Asstt.
Commissioner to be 5090 (DR 300 + promotee 4790) and 2118 posts of Asstt. Commissioner
to be regularized as part of separate Branch B service. Number of Asstt.
Commissioner is required to be enhanced as one Asstt. Commissioner upto maximum
2500 assessees per Division. For Headquarters, Customs, Directorates etc., even
more Asstt. Commissioners are required. In original GST model, there were
250-300 assessees per Range means 1250-1500 assessees per Division for smooth
functioning of GST work.
3. However, it is
again submitted that we would be able to make complete submissions on the
proposal only when we are provided complete copy of the proposal instead of
selective presentation. It is further submitted that the methodology adopted
for determining manpower requirements, including the allocation of man-days for
activities such as verification, scrutiny, recovery and other field functions,
may merit reconsideration. Any underestimation of workload can significantly
impact the assessment of the actual requirement of field officers.
4.
We are also of firm belief that a re-examination of the comparative revenue
performance of SGST and CGST formations may be necessary taking into account
the following factors:
(i) The numerical
strength of SGST officers per unit assessee is significantly higher than that
of CGST officers in the most of the States.
(ii)
The distribution of taxpayers across CGST Zones requires reassessment.
(iii) In several State GST
administrations, the equivalent supervisory position to a CGST Superintendent
is an Assistant Commissioner, which may affect comparative analyses and
manpower assessments.
5.
We understand that DGHRD has constituted three groups namely Working Group, Customs
Group and Future Group for examining various aspects of the cadre
restructuring. As a recognised stakeholder representing a significant segment
of officers directly affected by the proposed reforms, we respectfully submit
that the representation of Association in these groups would facilitate broader
consultation and contribute valuable field-level perspectives. Inclusion of
stakeholder representatives would also enhance transparency, participation and
acceptance of the recommendations emerging from these groups. So, it is
requested to kindly make representation of the Association in all of such
groups. If the groups have submitted their reports, the same may kindly be
provided to the Association for positive deliberations.
6.
It is also submitted that the basic data and parameters considered by DGHRD in
arriving at its proposal may be revisited and re-examined to ensure adequately
reflecting the present operational realities and manpower requirements of the
Department. It is felt that the underlying data and methodology adopted by
DGHRD warrant a fresh review as any inaccuracies or omissions in the baseline
data could significantly influence the assessment of manpower requirements and
the resulting cadre restructuring.
7.
It is observed that the State GST (SGST) administrations have developed a
comparatively robust and well-distributed human resource structure, which
appears to have contributed positively to their operational efficiency and
revenue performance. A notable feature of SGST organisations is the active
involvement of officers at various levels, including senior Group 'A' officers,
in revenue-related and field-oriented functions. Such an integrated approach to
revenue administration may merit consideration while assessing organisational
effectiveness and manpower requirements in Central GST.
7 (i). It is also
pertinent to note that, in a State, a relatively streamlined administrative
structure under a single Commissioner has demonstrated encouraging results in
terms of revenue mobilisation and taxpayer management. This experience may
provide useful insights for evaluating existing organisational arrangements and
resource deployment patterns within CGST formations.
7 (ii). Accordingly,
while undertaking cadre restructuring and manpower assessment, a comparative
study of successful administrative practices adopted by SGST organisations may
be beneficial in identifying the measures that could further enhance the
efficiency and effectiveness of the CGST workforce.
8.
The Association remains committed to constructive engagement with the
Department and fully supports efforts aimed at strengthening the organisation
and improving administrative efficiency. We respectfully request that the
concerns and suggestions outlined above be given due consideration while
finalising the cadre restructuring proposal, so that the interests of the
organisation as well as its officers are appropriately balanced.
9. As Asked by your goodself to get
sent suggestions on mail Id cr.hrm1@gov.in by the individual officers and also
by the Association/s, it is submitted that the relevant due additional
submissions would be made based on the deliberations to be made by the
associated units & delegates in Associate Executive Committee meeting of
the Association being held on 27.06.26 as also requested vide Ref. No. 37/AIB/C/26
Dt. 08.06.26 of the Association. So, the referred mail Id may kindly be kept
open giving sufficient time to the stake holders.
10. In the meantime, it is
requested that all the submissions made earlier by the Association including Ref.
No. 37/AIB/C/26 Dt. 08.06.26 may kindly be given due consideration.
11. We look forward to continued
dialogue and meaningful consultation on this important matter.
Thanking you,
Yours
sincerely,
(HARPAL SINGH),
Secretary
General.
