F. No. AICEIA/Mumbai/Misc/2016

                                                                               Mumbai, the 12^th April, 2017

To,

The Chief Commissioner,

Central Excise, Zone-I,

Cadre Controlling Authority,

Mumbai.

Sir,

Sub: - Proposed restructuring/reorganization of Department consequent

to rolling out GST from July 2017 – reg. 

             With the passage of the GST from both the houses of parliament, the major indirect  tax reform of the century is just few steps away before becoming part and partial of our robust tax mechanism, which in all probability will be effective from not later than July, 2017 as has already been reckoned by our Finance Minister. This historic event will require administrative changes as well as organizational changes in the entire formation.

           

             As has been in all the cases, this time also all the officers of the department had given their utmost support, and are not leaving any stone unturned so as to make the rollout GST successful. All the officers have successfully undergone training for the same and are ready for any challenge that may come on the way after GST rollout. However, it is a universal fact that human beings are bit receptive as well as apprehensive for any drastic and phenomenal change, and these human values can’t be ignored in the case of departmental officers too.

             Further, it is a universal fact that the life in Metro and the suburban area of Mumbai has its own impact on all the residents, and same can’t be ignored in the case of cadre officers who has to make use of public means of transport, commuting in which at the peak hours is a tough nut to crack which drains out lot of energy which otherwise could be harnessed in productive official work. Advantages and disadvantages are there, but everyone has to manage their best under the given circumstances.

             The members of AICEIA, Mumbai Circle are also worried, considering the past experiences. Hope that in the near future, all these apprehensions, as what will be the structure, how the staff will be deployed in the new tax regime etc., will be set to rest.

The factor most affecting, both the trade as well as staff in the field, is the infrastructure provided, which always has been a grey area with even basic amenities of office becoming a cause of struggle, for the lower staff. AICEIA Mumbai suggests and requests that immediate steps be taken so that all the infrastructure issues are sorted out on priority basis. If required, the stake holders may also be involved in the process of deliberation and inviting suggestions in the matter.

            Board has finalized the number of Commissionerates in our Zone i.e. 11 Executive Commissionerates with 650 Ranges, 5 Audit Commissionerates and 5 Commissioner (Appeals). While finalizing the Headquarters office and its Division/Range/Circle, adequate precautions be taken, so that it is convenient, both for the trade as well as field staff, majority of whom resides at far away suburbs of Mumbai (from the commutation point of view). For example, the Commissionerate of Thane/ Thane rural/ Bhiwandi/ Palghar are having jurisdiction which are adjacent to each other. So is the case with the Commissionerates of Mumbai East/South/Central/West and Raigarh, Belapur & Navi Mumbai.

                As has been represented by the association in earlier occasions, it is once again reiterated here that the welfare of the trade alongwith the same of the officers should be the guiding principles during GST reorganization. All the efforts should be such that the headquarters should be in the jurisdictional area itself so as to facilitate the trade. Further, the posting of the officers should be done based on the place of residence so as to bring out the maximum efficiency from all the officers.

            Although Board has finalized the number of Commissionerates/Directorates and other subordinate offices, we feel that the Administration does not have proper data, either as to how much of the assesse-base will be lost to the State Administration or how much of the business activity will be gained by us. Hence, the Association feels that it is premature at this juncture to go in for reorganization.

             The traditional method of bifurcation of the jurisdictions, as happened during the Cadre Restructuring of 2014, will not be applicable now. Further, the new tax regime will be based on the concept of ‘principal place of business’. Mumbai will have a major share, whereas the activity in the Commissionerates of Palghar, Bhiwandi, Thane Rural, Belapur will remain only in name, as the major taxpayers in these Commissionerates have their Head offices and therefore ‘place of business’ in the city of Mumbai. Also, various large taxpayers, now attached to LTU-Mumbai, needs close consideration, while creating / shaping Commissionerates. Revenue and the work load of each Commissionerate will not be uniformly even, by any yardstick or parameter.

            We are also aware that our current network system is incapable to cope with the new system. For the failure of the system and lack of its up-gradation, the officers are being subjected to harassment. Hence, this aspect may also be looked into.

             A wholistic approach needs to be followed keeping the welfare of all the stake holders into account. We understand that change is an important part of life, but if it is done after taking into confidence, all the constituents, then the process of change is smooth and good for the entire organization and its stake holders. But if the same is done unilaterally, then it becomes a cause of unrest and resentment.

             We hope that the Administration will not allow the situation to degrade to such an extent and the Administration, under your kind control, will involve all the Staff associations to be part of the deliberation and will move with pace to adopt the changes, for the betterment of all.

           

Thanking You,   

        Yours faithfully,

                                                                          

                                                                                          Sd/- 

                                                                              (ABHISHEK SINGH)

                                                                                 General Secretary

 Copy to: The Chief Commissioner, Central Excise, Mumbai Zone-II & Chief Commissioner, Service Tax, Mumbai Zone – For kind Information & necessary action.