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Date: 20-11-2010


1. Com.Arun Zacharia,

2. Com.Kousik Roy,
Secretary General,

Dear Comrades,

Sub: Proposals for Cadre Review/Restructuring – suggestions – Reg.

The views and suggestions of the AICEIA, Hyderabad Zone Branch on the
proposals for cadre review/restructuring are enumerated below.

1. Board's decision to create service tax commissionerate for Rs. 3000 crores of
ST revenue and/or assesses base of 17500 or more will entitle Hyderabad
Zones to have one more Service Tax Commissionerate instead of one as has
been proposed as the ST assesses base of Hyderabad Zone is around 37000
by the end of March,2010. This assesses base is expected to see exponential
growth in the foreseeable future and Hyderabad Zones requires atleast two
exclusive Service Tax Commissionerates instead of one for effective
implementation of Service Tax Law and augmentation of service tax revenue.
You are requested to press for one more service tax commissionerate in
Hyderabad Zones as this will also mitigate the stagnation in Inspector cadre
due to availability of 80 more Superintendent posts if one more
Commissionerate is created.
2. One exclusive Customs Commissionerate for Airport and ACC is proposed in
Hyderabad, but what about two ICDs functioning in Hyderabad. When they
say exclusive Customs Commissionerate for Airport and ACC, does it mean
that the two ICDs that are functional in Hyderabad as on date are part of
ACC. But Board in it's proposals in one page says that it will be attached to
Vizag Customs Zone and in another page it says that it will be attached to any
one of the two zones of Hyderabad. For administrative and geographical
convenience it should be attached to any one of the two Hyderabad Zones as
the proposed Vizag Customs Zone is situated away by more than 600 Kms
from Hyderabad. Since this being land customs, hitherto it is being managed
by Central Excise Officers only and as such all the posts of Superintendents
and Inspectors should be allotted to Central Excise in the proposed
restructuring. You are requested to prevail upon the Board to tag the proposed
exclusive Customs Commissionerate in Hyderabad to any one of the two
Zones of Hyderabad.
3. Out of around four thousand AC posts available on account of this
restructuring, after reserving 50% for DR quota, the balance have to be shared
by Supdt, Appraisers and Supdts (Customs). What a pity. It is incongruous
and incompatible that we i.e. Examiners, Inspectors-CE and POs are recruited
by same agency, with same syllabus and are governed by same Board, why to
have separate track of promotions benefitting a negligible but powerful lot and
discriminating the hapless majority. What is so sacrosanct about these
Customs cadres as not to merge these cadres with CE and make a single,
viable and unified Group-B cadre in CBEC. What has happened to the
Resolution of the Board in 1999 or 1998 and the recommendation of
Bhardwaj Committee for merger of all analogous posts in CBEC. When the
Government of India is limping towards merger of all taxes and introduction
of one single indirect tax i.e., Goods and Services Tax with common rules
and regulations all over India, Board is merrily and gleefully perpetuating the
vertical division of Customs, Central Excise and Service Tax in Group-B
4. It is seen from the proposals that the restructuring proposals are made to be
compatible in the post GST scenario also as the number of Commissionerates
proposed in the Proposals are nearly same as the number proposed by GST.
But what about staffing requirement and pattern and with the expected
increase in assesses base by 25 to 30 lacs once GST is rolled out, the proposed
manpower particularly in Group-B will be woefully inadequate and these
officers will be burdened to shoulder additional workload as has been the
case during the last decade after introduction and expansion of Service Tax.
5. Even otherwise also it is debatable whether the sanction strength of 80
superintendents and 120 Inspectors for every Executive Commissionerate is
sufficient as the manpower for all the Directorates, Nacen,
Appeals/Adjudication Commissioners, Airport, ACC/ICD is deputed from
these executive commissonerates. Managing of a Commissonerate with just
80 Superintendents and 120 Inspectors with five Divisions and twenty five
Ranges and all sections including Anti-Evasion in HQRS, of course, without
audit, may result in additional workload to these officers. Board may be
pressed for increase in staff strength in Group-B Cadre in Executive
6. Why not all Directorates like DRI, DGCEI, DG-Inspections,DG-Audit,DGST,
DGHRD etc. NACEN, and all Commissionerates from Sl.No. 4 to 18
mentioned in page nos. 83 & 84 of Board's Restructuring Proposals and
Pr.CC office, CC office, have their own sanctioned posts of Group-B instead
of drawing from executive Commissionerates. Whereas, all these Directorates
and other formations have the sanctioned strength for IRS Officers, why not
the same yardstick is applied in case of Group-B. Whatever problems that
may crop up on account of deputations to these Directorates from all over
India and splitting of sanctioned strength among these Directorates can be
overcome with a little bit ground work.
7. The creation of Principal Chief Commissioners, upgradation of all the
Directorates and introduction of Grade-I & II posts in commissioner cadre
only strengthen the growing grouse among the Group-B Cadre that, like
previous cadre restructuring, this time also fruits will be enjoyed by them
only. When ACES is outsourced and being maintained centrally at one place
what role the Directorate General of Systems at locations other than Delhi
would have? Since the entire DG(Systems) work is handled by only a handful
of tech savvy and talented Inspectors or Superintendents, posting of high level
IRS officers may be unwarranted in Systems offices. Similarly for other
Directorates also there appears to be no need to upgrade them to Chief
Commissioner level or Principal Chief Commissioners level as it would not in
any way help in better augmentation of revenue or better utilization of
manpower or better management of the administration.
8. Board is silent about posts allotted to SEZs. It is not made clear as to whether
the posts allotted to SEZs as on date will be absorbed into the proposed
sanctioned strength of each cadre or whether these posts are over and above
the sanctioned strength for all the formations. Board may be prevailed upon
not to treat the SEZ posts as part of the sanctioned strength shown in the
9. Board’s attempt to push the proposals for promotion to AC from amongst the
three feeder cadres based on the old formula of 6:1:2 when the revision of
this ratio for promotion is still pending in Supreme Court smacks of
favouritisam and divide and rule policy. If all the feeder cadres are not
merged, at least Board should be bulldozed to change the formula in our
favour pending the decision from the Supreme Court.
10. What is the necessity of LTUs once the GST regime is rolled out. The very
concept of LTUs should be opposed tooth and nail as it will entail backdoor
entry of outsourcing.
11. When all the taxes are proposed to be merged sooner than later into one tax
i.e. GST, creation of exclusive Commissionerates at this juncture may appear
to be premature and unnecessary. Instead, exclusive Anti-Evasion and
Adjudication Commissionerates may be created for effective and economical
prevention of evasion of taxes and for speedy disposal of litigations.
12. With the acute stagnation that is prevailing in Group-B cadre and due to
which the kind of frustration, distress and disenchantment that is prevalent
among the Group-B cadre, not-adopting the total length of service in Inspector
and Superintendent cadre put together for promotion to Group-A is
incomprehensible and reprehensible. Unless this yardstick is adopted, Board’s
restructuring proposals will be nothing but mere lip-service and cosmetic
exercise. Pressure may be mounted on the Board to consider the total length of
service in Group-B for consideration of promotion to Group-A cadre.
13. All the additional posts of around 4000 in AC cadre may be allotted to the
promotee quota as a one time measure in this restructuring to remove the
stagnation in the Group-B cadre and Recruitment Rules may be amended
accordingly. If not atleast the ratio of 50:50 may be changed to 75:25 in
favour of promotee quota.
14. Like in the previous restructuring exercise during 1999/2000, Board is
proposing to abolish total posts of 6906 in CBEC with 3225 posts in Group-B
(NG) i.e. Inspectors cadre itself as cost cutting exercise and to show savings in
the present exercise. When the FM himself states that the cadre of Inspector is
the cutting edge level in the CBEC and has publicly opined that this cutting
edge level cadre has to be trained and motivated properly, CBEC thinks
otherwise and proposes abolition of these posts making a mockery of
suggestion of the FM and reports of various Standing Committees on Finance.
Additions in IRS cadre and abolition in Group-B(NG) levels.

While preparing your report to the Board on restructuring proposals, you are
requested to incorporate the points at Sl.No. 1 to 2 above in respect of Hyderabad Zone
in particular and to take into account the rest of points so that a detailed report is
submitted to the Board.

Further, you are also requested to take up the matter of Chennai High Court’s
judgement in 5400 GP issue with the Board. Without the help of any Association in
Group-B, the resolution, determination and grit with which Sri M. Subramanyam has
fought and mounted this legal fight is commendable. Since the matter has reached Board
level, it is necessary for the two Associations i.e. Inspectors and Superintendents to take
up the matter with the Board for accepting this High Court’s Order. It is not known
whether the Board will file a review petition in the High Court itself or settle for SLP in
the Hon’ble Supreme Court. In any case, both the Associations should engage the best of
the legal brains to assist Sri M.Subramanyam in future litigation.

Thanking you,

Comradely yours,

General Secretary