FROM CESA'S ARCHIVE

Representations submitted by CESA Mumbai to Chairperson on 28.10.2017 in person.

Ref:  CESA/15/2017

Date:  28^th Oct.2017

To,

The Honourable Chairperson,

Central Board of Indirect Taxes and Customs,

Ministry of Finance,

Department of Revenue,

North Block, New Delhi

Respected Madam,

Sub: - Visit to Mumbai GST Zone on 28.10.2017 for Cadre and Zone

            Specific issues for effective implementation of GST – reg.

We at CESA, Mumbai, welcome you to Mumbai, and thank you for responding to our request and giving us your valuable time from your hectic schedule.

As directed by your goodself, a representation on the issues as discussed with you and Member (Admin) on 28.10.2017 at Mumbai are enumerated below for your kind implementation and action please.

Shifting of CGST Commissoinerates in respective Jurisdiction: The Executive Commissionerate in GST ,Mumbai viz. Bhiwandi, Palghar, Thane Commissionerates, are not at all looking into this aspect despite the instructions from Board and PCCO office. In past also on such issues majority of the HOD/Commissioners are doing only cosmetic work and junior officers are working in a ‘shifting mode’ since implementation of GST. Madam, this is our humble request to direct the Executive Commissionerates to shift in their respective jurisdictions immediately within a given time frame.. Further they may be directed that advertisements for hiring of buildings be given immediately and acted upon immediately and a status report be called from them.

Recasting of All India Seniority of Superintendent Central Excise (Now CGST): This is also a grey area wherein all kind of malpractices are going on and CESA Mumbai has pointed out time to time and DGHRD was kind to hear our plea and looked into the issue and rectified the Omissions’/Commissions committed in seniority list. But the sad story is that the seniority list itself is now like Bamboo tree flower blooms not even once in decade in CBIC. Since 2006 there is no seniority list at All India level. The last one was for the period 01.01.1998 to 2006 Jan, issued in 2011 or so. This is in contrary to the DOPT guidelines on the subject. Despite having a full fledged DGHRD at apex level. We request you madam that, Seniority should be revised by taking into account ‘N.R.Parmar judgement’ and while redrafting it the clause of ‘Step up’ should also be incorporated. Recasting of seniority list is not a rocket science and can be done digitally on excel. DPC may soon be conducted after revising the seniority list.

Stagnation Committee report: Needless to say that stagnation Committee report should be applicable to only those officers who are ‘stagnating’ and should not applicable per se to all.  As discussed therein in the meeting with your goodself and Member (Admn)  that one time relaxation can be worked out on this, so that stagnation is removed and all are brought at par.

Madam, it is suggested that,

Ø  Lateral shift of officers to big firms like SBI/ LIC /Insurance/Finance/Taxation firms so that officers can come back and serve the government better.

Ø  Approaching other ministries that require our skill sets, and offer them services on deputation.Issues such as GST, border protection, financial investigations, trade procedures GST tariffs are some ares that may interest other organizations. Some such as are DG (shipping),DGFT, DGAD,DEA, DFS,SCI,Agriculture,Corporate Affairs,ROC,Heavy Industries, Home and other Ministries dealing on industry sectors. This can also be worked through central staffing scheme.

Ø  Creating and approaching large Government departments/PSU’s such as Railways, ONGC ,IOCL, NTPC etc wherein we can go and assist them in implementation of GST and plugging possible revenue leakages as they procure input/input services from large number of vendors.

Ø  Various States should be asked for and a policy be devised wherein we can be posted there for effective implementation of GST. I am sure many states will be short of officers since GST is a consumption based tax.

The above suggestions are only indicative in nature and further options, opinions and out of box ideas may also be asked for. In this way Superintendents can go to different organisations and work with repute since our career prospects are limited in CBIC.

APAR System: It is suggested that all APAR should be digitised and should be filed online as in the case of sparrow system for Gr.A. This will minimise the issues of not getting a vigilance clearance and APAR during DPC and will entail clarity. All Group ‘B’ gazetted officers, Superintendents, APAR should be filed and available online and modalities can be worked out for its implementation at the earliest. This will be a positive step towards Digital India.

 Customs reorganization: In the ensuing Customs Commisionerates reorganization, it is suggested that creation  of new Customs Audit Commissionerate , new Divisions and Preventive Customs Commissionerates in Zones may be created where there are no Customs Commissionerates at present. In the established Customs Commissionerates like in Mumbai/JNCH/Kolkatta officers  from CE should also be sent in all Customs Audit/Preventive, say @ 50% of the strength, and a process of amalgation should be taken up in right spirit.

Uniformity in matters; A well defined policy guidelines are immediately required so that in CGST we can correct the old deficiency:

         i)    Officers Uniform guidelines and Policy be framed soon or it can be done away with.

         ii)   Centralized ID Cards to all the officers in Zone.

         iii)  Colour Codes and format of ID Cards should be uniform all over the Country.

         iv)  Letter head, and other correspondence material of the department should be same all over.

         v)   Culture of running office on whatsapp should be minimized.

         vi)  Ensuring that the policies made are implemented in field formations for example vehicle policy  

               is made but it is not implemented as it is meant for.

Madam, issues are many and expectations are even more, we know that there exists no magical wand to change things instantly, but sincere efforts without any discrimination will certainly change the path and fold of the CGST fraternity.

Thanking you.

                                                                                                     Your sincerely,

                                                                                                                 

                                                                                                               ( Sanjeev Sahai )          

                                                                                   Jt.Secretary (WZ)-AIACEGEO

                                                                                         Jt.Secretary-CESA Mumbai

Copy to:  Ravi Mallik, Sec.Gen AIACEGEO

                via e-mail