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
Mob.7780255361 mail
Id:ravimalik_sweet@yahoo.com,
Site: cengoindia.blogspot.in Mob.9868816290
Vice Presidents: Apurba Roy, P. C. Jha (East); A. K. Meena,
Somnath Chakrabarty (west); Ashish Vajpayee, Ravi Joshi (North); B. Pavan K.
Reddy, M. Jegannathan (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 T reasuer: 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. 310/AIB/R/18 Dt.
26.11.18
To,
Dr John Joseph,
Special Secretary & Member, CBIC,
North Block, New Delhi.
Sub: Workload of
officers working in the Ranges.
Sir,
Kindly
refer to the DO letter Dt. 14.11.18 of your goodself on the subject mentioned
matter.
2.
It is to submit with due regards that the workload being faced by the officers
working in the Ranges is being presented by the Association regularly before
the administration. It is reiterated that they are overburdened on account of
innumerable reports which are being asked every hour from them despite of the
fact that the same can be produced centrally by the proper use of the system.
They are working with more than 1000 assessees per Range in comparison to 300
with the State GST counterparts in the circles as average. Many Ranges are also
having the assessees even to the tune of 12000-14000. They are also working
with acute shortage of manpower (1 to 1.5) per Range also with additional
charges in comparison to 5 in the State GST as average without any additional
charge. The State GST officers have been provided one four wheeler vehicle per
Circle for efficient disposal of work whereas no vehicle is provided to our
Ranges. This all has very well been depicted by Sh. B. B. Agarwal in his note
sent to the Board. If we talk in terms of pay scale and career prospects, the
officers working under State GST Circles are also having higher designation,
career prospects and pay scales than the counterparts working in the Ranges
under CGST despite of being same level. Our officers in Ranges are working even
without required infrastructure, proper and prescribed office space, prescribed
facilities and amenities and also without due resources.
3. The Association believes that the intention of your
kind letter is also to use the system properly and meaningfully to relax the
officers working in the Ranges who are really having no time due to being
overburdened and also being forced to work beyond office hours and
holidays under tremendous pressure.
4. The Range was designed to working cell of the
department. Over the years, the work of the Ranges has shifted from physical
control, supervision, assessment, permission to today where no interaction is
supposed with the taxpayers. However, the administration has apparently not considered any change in functions or formation of
the Ranges. Every sundry work is assigned to the Range offices whether comments
on the orders of legal courts or comments on the complex issues of law or
statistical data which can be easily availed centrally without asking from the
field formations.
Every work in
the department is initiated at the Range level without any recognition. Even the
tone and tenor of the letters and verbal directions are always appalling
creating panic, pressure and tension.
5. One of the best examples
is the expected Physical Verification of the taxpayers as per the ‘risk’
factors identified by the system. From the figures available, no report can be
generated regarding this. It is estimated that more than 50% of the total
taxpayers have been identified as having at least a risk factor and there is no
instruction on which risk factor/s are to be prioritized. The advisory requires
the officer to use a smart phone to identify the longitude and latitude of the
taxpayer and it is mandatory though not a risk factor. So, the taxpayers not
selected for Physical Verification would not have this mandatory field filled. If
it is so important, it should be a mandatory field for registration itself. If the
officer has to visit the location of the taxpayer mandatorily, the location
cannot be identified even with a Smartphone under the circumstances. There is
no provision for transportation of so many officers to so many locations and no
Smartphone has been provided to the officers. The administration has not given
a thought for providing the due infrastructure, necessary for the demanded work
to be done. However, a progress report of the same is definitely required. Thus, it can be seen that verification is a
time consuming process and efficiency and expediency depend upon the response
of the tax payers and subsequent monitoring and submission of documents in
time. Therefore, great amount of man hours of the Executive staff are spent
generating, verifying, compiling and monitoring various reports so that
authenticated information sent to the higher authorities.
6.
Even the report asked by
your goodself is required to be given by each Range Officer on daily basis.
Many man hours cannot be accounted in 20-22 days a month. For example, at least four meetings/Video Conferences in a month
means 4-6 days (preparation & compliance) for almost all officers. RTI;
Rajbhasha/Vigilance/Swachta pakhwaras, Special refund drive fortnights,
taxpayer outreach programmes/hand holding, preparation & compliance for
inspections by DGPM, Parliamentary Committee on Rajbhasha & others, CERA
audit & compliance, Legacy matters relating to refunds and otherwise, SCNs, Adjudication, verification of
returns (MFR/risk based) etc. take time which cannot be quantified. Study of
legacy laws and GST laws for understanding & proper invocation on case
to case basis may take a lot of time and brain storming. GST work relating to
Non Filers, TRAN-1 verification starting from old returns, sensing doubtful/abnormal
credit, checking various documents with GST transitional provisions takes so
much time and energy with the GST portal showing technical issues frequently. GST
refunds sanctioned and paid through PFMS take their own
time. Refund claims received from States for payment through PFMS,
cancellation of registration, GST practitioners registration, random
checks of returns for revenue and other reports like MPR, periodical reports alongwith
ad hoc reports/informations are other areas of work. The work further includes
appeals to be filed before Commissioner (Appeals) & CESTAT, parawise
comments for filing appeals before CESTAT/Courts, going through the cases and
case laws to brief the Counsel, responding queries of taxpayers, visits to sensitive
taxpayers to file returns etc. It takes whole
day to cover just 2-3 taxpayers to get registered. Time taken in cases of
inquiry and investigation depends on nature of each case. Work relating to
E-way bill etc. is an additional work consuming a lot of time beyond working
hours.
7.
The
computerization in the Department actually took care of day to day work neither
in pre-GST nor GST era, that’s why the officers are overburdened and forced to
look into every matter manually. The digitalization of data is still under
development. Besides that the legacy work is still under process. The following
points may give a picture of our overburdened officers working in the Ranges
under tremendous pressure-
(A) Multi fold increase in number of Tax Payers:- The number of
registered assessees in pre-GST regime were much less. The threshold exemption
limit has been set to Rs. 20 lac only which was Rs. 150 lac in the Central
Excise regime which has resulted into increase in number of assessees.
Moreover, this Department was dealing only with manufacturers and service
providers in pre-GST era but presently, all sources of business/supply of
goods/supply of services have been added to the scope of work and this is
another reason for increase of number of assessees. The Taxpayers are facing
various difficulties in meeting with their GST obligations and they frequently
contact the Range Officers for solving their problems. The Department has
already communicated the mobile numbers of the Range Officers to the assessees
and for this reason, the officers have to spare a good time for solution of the
problems being faced by the Taxpayers.
(B) The GST network is not perfectly developed till date:- It goes without saying
that the GST network is still in the process of development. The Taxpayers as
well as the departmental officers have been facing a number of troubles on the
system. The solution to these problems is awaited from higher levels. The system
is slow and takes a lot of time. The electronic working is not smooth, user
friendly and time saving as was expected.
(C) Insufficient information given by the system:- Previously, in pre-GST
regime, the details/ figures of turnover, value and duty/tax paid in cash and
through credit account were being obtained from the individual assessee every
month. The data so obtained was used to maintain assessment register reflecting
complete details (commodity wise/service wise) in respect of individual
assessee. This data was useful and also helpful in generation of any kind of
information like commodity wise duty payment, service wise tax payment, top
assessees, top commodities, top services audit schedule etc. This data was also
useful for preparation of information pertaining to the parliamentary
questions, RTI etc. However, the system now is providing only raw data in
respect of taxpayers and that too incomplete. Such data has to be further
processed for adhoc reports, parliament question, RTI applications etc.
Therefore, the time consumed in reporting has not been reduced but increased.
(D) Continuation of reports:- It was expected that the GST
network would well prepare all source of information required for the purpose
of indirect tax administration and no report would be required to be prepared
by the subordinate offices/field formations. But the authorities at different
levels are seeking reports from their subordinate offices/field formations continuously.
The most of the times, the reports are called on urgent and immediate basis
creating panic and pressure. Unlike the previous tax regime, such reports are
forwarded to the Range levels. The GST system frequently fails to provide the
necessary content for generating the reports resulting in consumption of huge
time.
(E) Field works required to be conducted in GST regime:- Needless to
say that any type of tax generates the revenue for the Government but evasion
of the tax also goes simultaneously. There will always be evasions and
litigations in any kind of tax regime on account of the tax evasion. The GST
Law has also provided preventive measures to curb evasion of tax. There are
provisions of checking of e-way bills on roadsides, scrutiny, audit, searches
etc. for the safeguard of revenue. Such provisions require the officers to
visit out of the office leaving aside the table works having no limit of time. Such field works can only be performed
manually and the computer system is of no use for this purpose. Presently,
the staff available does not suffice to meet the requirements of the fieldworks
due to acute shortage of manpower. In the case of the officers being engaged in
the field works, the official table works remain held up completely because the
Range Offices are being run by only one Superintendent and less than one
Inspector and many of whom are having additional charges. Thus, much more manpower
is required for an efficient field as well as office working.
(F) Issues relating to notices, adjudications, recoveries,
litigations etc.:-
The issues relating to the notices, adjudications, recovery of tax & other
dues, litigations etc. are almost the same as were in the previous tax regime.
These all used to take considerable time and will continue to demand more time
and mental as well as physical labour in the present system also. The
electronic system will be of no use for the aforesaid procedures and such works
are to be carried out manually only.
(G) Legacy works:- The legacy works
pertaining to the Central Excise Act, 1944 and the Finance Act, 1994 are not
over till date. The officers have been directed to carry out the scrutiny of
the returns. There are also the cases of verification of the third party data
received from the Income Tax Department which requires the officers to verify
the taxability and tax payment of the amounts received by the parties. This
verification is time consuming. Similarly, the detailed scrutiny of ST-3
Returns is also under process. Furthermore, there is no way to dispense with
the cases of recovery of the Government dues since most of the cases are lying
in appeal with higher authorities and courts. These cases demand attention and
time on regular basis. The legacy works with the department cannot be ignored and
the same is also the significant reason of overburdening of the officers working
in Range Offices.
8. In nutshell, the officers
working in the Ranges are performing the following work functions among others-
1.
Generation of revenue
reports from the AIO dashboard and compilation of the same.
2.
Processing of amendment
in registration/cancellation of registration requests/amendment in Email Id,
professional address and phone numbers of the assessees.
3.
Handholding/guiding
and clarifying the issues being faced by the tax payers and taking up the issue
at the appropriate level so that the problem faced by the tax payers get
resolved.
4.
TRAN-I verification of
the list supplied by the Headquarters and necessary correspondence with the tax
payers for verification of the documents on the basis of which they have taken
the credit. TRAN-1 verification starting from old returns, sensing
doubtful/abnormal credit, checking various documents with GST transitional
provisions.
5.
Verification of the
difference between GSTR-1 and GSTR-3B figures and reporting of the same.
6.
Identification of
non-filers and issuing notices to the defaulters as persuasive measure so that
returns are filed along with payment of due tax liability.
7.
Visit to non-filers,
which itself is time consuming keeping in view the shortage of the manpower.
8.
Verification of the
difference between credit taken in GSTR-2A and GSTR-3B figures and reporting of
the same and in case of discrepancy,
taxpayer is asked to reverse the excess credit in the GSTR-3B return to be
filed in the succeeding month.
9.
Processing of GST
Refunds/consequential relief refunds in a time bound manner.
10.
Initiating
registration cancellation proceedings on voluntary surrender requests of the
tax payers after determining the tax liability.
11.
Refund claim received
from the states for payment through PFMS, random checks of returns for revenue
and other reports like MPR, periodical reports with ad-hoc reports/informations
and other areas of work.
12.
Study of legacy laws,
GST laws (transitional provisions) for understanding and proper invocation
consuming time and requiring brain storming.
13.
A number of
meetings/video conferences means a lot of time and effort being devoted in
preparation and compliance for almost all officers.
14.
Tax arrears recovery
involving persuasive action and necessary correspondence with various
authorities for identification of the assets/property and subsequent reminders
for seeking desired information along with visits to the premises of the
defaulters.
15.
Legal matters–drafting and filing of appeals and submitting them to the
CESTATs and higher Courts, which also involve long travels to the place of
court.
16.
A number of programmes like Swwachta Pakhwada, Vigilance Pakhwada,
Special refund drives fortnights, taxpayer outreach programmes/handholding of
assessees, preparation and compliance for inspections by higher authorities, DGPM,
parliamentary committee on Raj Bhasha, CERA audit and other agencies
17.
Issuance of Show Cause
Notices pertaining to the Superintendent competency and drafting/forwarding of
Show Cause Notices to Asstt. Commissioner/Joint Commissioner/Commissioner of
their competency well in time.
18.
Delivery of Personal
Hearing letters/Show Cause Notices/Order-In-Originals and Order-In-Appeals
received from other divisional formations/ Hqrs and drawing Panchnama on the
spot, if the assessee is not available at the given address.
19.
Verification of the
invoices/documents mentioned in the letters received from other Divisional
formations/Commissionerates and submit the verification report to Division
office for forwarding it to the respective jurisdiction under dated
acknowledgement.
20.
Aiding the Hqrs
(Preventive/Anti Evasion) staff in their operation as and when they require for
carrying out necessary proceedings.
21.
DAK
correspondence/email checking and taking requisite action thereon accordingly.
22.
Officers from Ranges
are also deputed for E-way bill checking.
23.
Preparation of weekly
reports on refunds, daily registrations, Suo Moto cancellation and non filers.
24.
Preparation of
fortnightly reports on Non-Filers, GSTR-1 and GSTR-3B difference, GSTR-2A and
GSTR-3B difference, uploading of GST refund report on DDM, TRAN-1 credit
verification.
25.
Preparation of MPR
(Revenue and Non-Revenue) updation of the arrear cases and reporting recovery affected
in the monthly TAR report sent to the Hqrs.
26.
Preparation of the
Third Party report and taking requisite action for affecting recovery and
safeguarding Government revenue by issuing Show Cause Notices wherever
required.
27.
Updation and review of
the Anti Evasion legacy cases and taking requisite action accordingly.
28.
Updation of various
registers including GST refund registers/records and prepare abstract on
monthly basis.
29.
Updation and
submission of TRAN-I verification report on monthly basis.
30.
Attending the Court
proceedings in the prosecution cases and taking necessary correspondence with
the witnesses/formation to be resent for examination/cross examination.
31.
Follow up enquiry in cases booked by Anti-Evasion/Preventive.
32.
Writ petitions received seeking para wise comment from GST policy wing.
33.
Dealing with PMO references, Parliamentary questions, RTIs, CPGRAMs etc.
34.
Helping and providing
the visiting A.G. (Audit) teams with documents and records asked for conduction
of the audit proceedings of Range office as well Division office.
35.
Preparation of various
miscellaneous reports asked from higher formations like SIIB, DGCI etc.
36.
Preparation of
Inspection Note and updation of records on visits by the higher authorities for
the Division office as well as Range offices for conducting the yearly
Inspection.
37.
Holding the charge of
DDO due to acute shortage of AOs.
38.
Writing letters to the tax payers to seek clarification and submit
requisite documents for verification.
39.
Verifying that credit available on capital goods is not taken 100%
during the first year in their book of accounts.
40.
Checking of the succeeding GSTR-3B return to ascertain that the credit
has been reversed and debited.
41.
Physical Verification
in connection to the advisory for Physical Verification of Registration issued
by the DGS&DM.
9.
No need to say that there may be many other unforeseen and unseen various types
of works being performed by the officers working in the Ranges. In actual
terms, they are being used as multi-purpose tools in our organization including
official as well as unofficial purposes/protocols.
10. Accordingly, the works being performed
in the Range offices may be briefed as below-
A. Legacy issues
A1. RnC work
A2. Preliminary Scrutiny
A3. Detailed Manual Scrutiny
A4. Third Party Investigation
A5. Draft SCN
A6. Preparing Regular Monthly Reports
A7. Comments on Reply to SCN
A8. Arrear Recovery
A9. Interest calculations
A10. Interrogatory statements
A11. Adjudication orders
A12. Serving of SCNs and Adjudication orders
A13. Compliance of Audit Reports
A14. Data analysis to detect cases
A15. Ad-hoc Reports in new formats on urgent requirement
A16. Check & verify challans deposited against CEX ST
B. GST issues
B1. Registration & Migration
B2. Generation of new user id/pwd
B3. Cancellation of Registration
B4. Tracing of non-filers
B5. Notice to non-filers
B6. Personal Hearing to non-filers
B7. Tracing of late filers
B8. Notice to late filers
B9. Interest calculation and notice to late filers
B10. Suo-moto cancellation Notice to non-filers of GSTR3B
B11. GSTR3B vs GSTR1 mismatch check
B12. Notice on B11 above
B13. Cash-Credit Ratio on GST payments
B14. Match Cash-Credit Ratio of post-GST vs pre-GST and analyse reasons
for changes
B15. GSTR3B vs GSTR2A
B16. TRAN1 verification
B17. Remove data on late fee paid from Reports of AIO to get cash paid
in GST
B18. E-way Bill verification
B19. Verification and Report on Refund Issues
B20. Ad-hoc Reports on new formats on urgent requirement
B21. Inspection and search operation under GST
B22. Data analysis to detect fraud of GST
B23. Interrogatory statement before SCN
B24. Issue SCN under S73 and S74
B25. Adjudication
B26. Helpdesk
B27. Address verification
B28. Processing of GST refund
B29. E way bill checking.
B30. GST Registration issue
B31. Monthly/ Fortnightly meeting with Division & Hqrs.
B32. Inspection/Audit of Range by CERA Audit team and rectification work
thereof
B33. Inspection by AC/DC.
B34. Various regular reports
B35. Keep ourselves updated with the daily changing effects of GSTN
Council meeting, Notification, Circulars, Act and Rules.
11. If we talk only in terms of
single point of refund, no need to say that this process in itself is very
complicated and
lengthy. This process of disposal of GST refund may be taken into account while
evaluating the performance/workload of Superintendents and Inspectors working
in the Range offices as every work being done by them may be lengthy, time
consuming and complicated in practical terms. Different Stages of GST refund
processing are depicted as below after the receipt of GST refund claim:
1. Individual file is opened after making entry in File Opening
register,
2. Entry is made in respective refund register prescribed for
the purpose,
3. After initial
checking, if need be, deficiency memo is issued to the party in time bound
manner and entry is made in respective register,
4. After receipt of reply from the party in r/o deficiency memo,
again entry is made in respective register,
5. Then the claim is checked with respect to completion of
documents. If found in order, acknowledgment is issued in time bound manner. A
unique number is allotted to the acknowledgment letter and entry is made in
respective register,
6. Copy of the claim is sent to the jurisdictional Range
Superintendent for verification of the claim/ pending dues against the party,
7. After initial checking of the documents, 90% of the claimed
amount is sanctioned within 7 days in RFD-04. A unique number is allotted to
the RFD-04 and entry is made in respective register,
8. In case of Central Tax, Payment Advice in form RFD-05 is
issued to the party and a copy to the A.O./P & A.O. A unique number is
allotted to the RFD-05 and entry is made in respective register,
9. Then, RFD-04 and claim of the party are scanned and provided
to the Divisional Assistant Commissioner for sending to the SGST/A.O. of the
Division, as the case may be.
10. One original copy of the order and copy of the claim is also
sent to the A.O. for sending the same further to P & A O.
11. In certain cases where refund amount appears to be
inadmissible, SCN in form RFD-08 is issued to the party and entry is made in
respective register. Thereafter,
adjudication procedure is adopted to dispose off the case. After adjudicating
the SCN, refund procedure is again initiated on merit of the case.
12. After issuing
provisional refund order, the case is taken up for final order in time bound
manner. At this stage, all documents are required to be scrutinized. After
scrutiny of the documents, inadmissible amount/adjustment is deducted and final
order in RFD-06 is issued. A unique number is allotted to the RFD-06 and entry
is made in respective register,
13. Again, in case of Central Tax, Payment Advice in form RFD-05
is issued to the party and a copy to the A.O./P & A.O. A unique number is
allotted to the RFD-05 and entry is made in respective register.
14. Then, RFD-06 and claim of the party are scanned and provided
to the Divisional Assistant Commissioner for sending to the SGST/A.O. of the
Division, as the case may be.
15. Brief Note/Review Note of the case is prepared and sent to
the Review Branch alongwith copy of the RFD-06.
16. Entire file is sent to the Audit branch for post audit
alongwith copy of the RFD-06. The assiduous task of photocopying the entire
file is done so that shadow file is kept in the branch for future reference.
17. Then, the inadmissible amount/rejected amount is required to
be re-credited in ECL of the party by issuing RFD-01B/ PMT-03.
18. Apart from above, there are many weekly/ fortnightly and
monthly reports in r/o refund which are sent to Headquarters. Sometimes, reports
on daily basis are also called by the Headquarter office.
19. Work related with Nodal Officer: The work related with
Nodal Officer requires one person dedicated for this task only. A lot of RFD-04
and RFD-06 orders are received from Nodal Officer of SGST department through
e-mail on daily basis. After taking print-out of the said orders, copies of the
orders are sent to respective jurisdictional Assistant Commissioners for
necessary action. In the respective Division, Payment Advice in r/o RFD-04/
RFD-06 orders is prepared and sent to A. O./ P& A.O. for payment. A
separate file for this purpose is being maintained in the Division.
20. Similarly, Nodal Officer has to forward all the RFD-04/
RFD-06 orders passed by CGST Divisions to the Nodal Officer of SGST department
through e-mail for further necessary action at their end.
12. Some of the major reasons causing
problems and troubles at Range level are as below:-
1.
Slow speed of GST
Portal.
2.
Applications of GST
portal are not in consonance with the requirement of report generation as
desired.
3.
Sometimes, assessee
applying for registrations or LUTs for export online do not get their work done
in time due to some statutory requirement or some technical glitches but all
such work is being dealt at CPC and aggrieved person contacts for resolution of
the issues in local office. System generated mail or CBEC Mitra helpline
instructs him to contact to local authorities but local authorities are not in the
position to solve the problems as their portal does not support so. Aggrieved
persons/their consultants argue endlessly and both time and energy of Range Officer
is wasted in such replies.
4.
Retrieval of data from
GST portal is herculean task as officer has to check details month wise,
assessee wise first and then to compile as desired. For example, list of
registrants is not in chronological order on the portal, revenue comparison for
a particular period tax payer wise or HSN wise is not available.
5.
The most of the Range officers are having
additional Charge of Division and of Headquarters. All works are to be dealt on
priority as all are time bound and of priority.
6.
The miscellaneous work
of regular reports, day to day reports, reports from GST portal for which
system is not inbuilt, letters of PH, Show cause Notices, Adjudication orders,
Personal hearings, letters returned undelivered, issuing reminders, visiting
places/sites for service of notices, work as Com Admin and GST cell, persons
visiting for their queries in GST help desk etc. require more efforts which may
take substantial time.
7.
It is not possible to
search the tax payer by its trade name on Range GST Portal. If any officer
wants to enquire the GST compliance of his jurisdiction by its name, it is not
possible until one has PAN number of the party.
8.
GST portal on OIA logs
out automatically and again logging takes time.
9.
In ACES, to scrutinizer-1/ER-3
or ST-3 returns of any assessee for each return from the list appearing, one
has to fill the assessee details, date and time period each time which consumes
much time.
10. All Ranges and additional work allotted to Range Officers are
being dealt with acutely short manpower. There is no availability of
ministerial staff for support work. There is need for proper allocation
of contingents for each Section on
account of insufficient sepoys/havaldars available for manual work of office,
arranging files, file movement, making
Photostat copies and arranging them in order particularly for preparing SCNs
and in adjudication etc. All these works require responsibility, know-how of
office procedure, substantial time and energy. So, skilled contingents are need
of the day. This situation is overall affecting performance of Range
Superintendent and his/her only one or half Inspector.
11. Sometimes, Range staff is not in position to understand the importance of
reports asked all of a sudden. For example, report of Cancellation of
Registration started to be asked suddenly is being asked now weekly and even
daily. Once screen shots of Range Officer GST portal were asked along with
report (by Lucknow CCO) on Whatsapp. This report was recently asked updated up
to 13th Nov, 18, then up to 15th Nov, 18 for CC Level Video
conference. Range Officers have to work in hurry as pendency is required to be
NIL. If all cancellations filed by the tax payers are to be approved in speedy
manner, such requests are not required to come to backend GST portal of Range
Superintendent.
12. It is also on record that work is also done on weekends by
the Range staff either under instructions of the Department or by own volition
of the Range Officers to evade any unwelcomed situation in the matters which
are time bound. Availing leaves has become the matter of past.
13. Thus, the practice of seeking
every report or comments every time from Range level should be examined in the
light of monthly reports and other letters sent by the Range and their availability
on GST or ACES portal. If any report is possible to be generated from higher
level in totality, it should not be asked from Ranges as efforts are multiplied
in that proportion. The Standard Formats of Daily/Weekly/
Monthly/Quarterly/Yearly reports should also be made in ZCDR (Zone,
Commissionerate, Division, Range) stages, so that all other reports may be
generated from those reports. In case of any new report, sufficient time and
its GST/ACES path and guidelines may be provided in covering letter as much
confusion remains and each Range interprets in its own way. For example, if GST
revenue and Non GST revenue comparison is asked over two years, it should be
cleared which components whether VAT, CENVAT, other taxes subsumed in pre GST
era or Central Excise Duty, Service Tax, Cesses etc. has/ have to be included
in Non GST Revenue and which components whether CGST, SGST, IGST, ITC of each,
Cess etc. has/have to be included in GST Revenue. CENVAT revenue of pre GST era
is not available in reports generated from ACES. It may be arrived only by
opening each monthly/quarterly/half yearly return filed by each tax payer at
that time. Such calculation is not possible by available means in the present
situation. Online Path to arrive at monthly data of GST registrants or data for
comparative revenue analysis of top taxpayers of Range or data of non-filers
who have filed returns and revenue deposited by such filers is not known to the
Range. Such reports asked in urgent manner on Email/Whatsapp worsen the
situation of work load in more stressful way.
14. The letter of the Chief
commissioner of Chandigarh/Panchkula and also your office response on the same
irrespective of outcome are self-explanatory to depict the acute work-burden
being faced by the officers working in the Range Offices.
15. The above submissions have been
made with the request to allot more manpower to Range Offices, especially
looking into the circumstances that the most of the officers are having
additional charges. The additional charges mean doubling/tripling of workload
and official troubles. Immediate provision for infrastructure for officers to carry out the
physical verification of registration, e-way bill verification, necessary
smartphones and vehicles are also required to be provided to commensurate with
the work to be done alongwith taking due steps regarding all of above
submissions.
Thanking you,
Yours sincerely,
(RAVI MALIK),
Secretary General.
