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COMMENTS/OBJECTIONS
1. The proposal lacks any vision or far sight and all that has been done is to
ensure systematic and time bound promotion to direct recruit Group A
officers and a largesse to their blue eyed boys- the Appraisers. The limited
benefit made available to Inspectors of Central Excise in certain cadre
zones are only incidental in the scheme.
2. The proposal fails to realize the problems faced by the Inspectors of Central
Excise. The major problems being
(a) Disparity in promotion among the 15 seniority zones of Central
Excise Inspectors.
(b) Disparity in promotion vis-à-vis Preventive Officers & Examiner
(c) Unfair ratio between Central Excise & Customs that grossly
discriminates Superintendents of Central Excise for promotion to
the post of Assistant Commissioner
(d) Skewed ratio for Group B Gazetted Executive to entry level Group
A posts
4. The present proposal would widen the disparity among the Central Excise
seniority zones as evident from the table below. At present the gap
between the best case and worst case is 10 years. (North East 1986 & Delhi
1996). This proposal would widen the gap to 15 years. (please see table in
Annexure A). While Inspectors of 2002 batch gets promoted in 7 out of 15
cadre zones, Inspectors in 8 Zones would lag behind as follows. The
situation is acute in 5 zones.
This huge disparity would de-motivate & demoralize officers in this zone
and doom their prospects permanently and would lead to prolonged unrest.
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5. The present proposal would widen the gap between Central Excise &
Customs in the matter of promotion to the grade of Assistant Commissioner.
While the 1995/96 batch of Superintendent of Central Excise only would be
promoted as Assistant Commissioner, the 2007 batch of Appraisers would
get their promotion. While all the Examiners of 2004 become Assistant
Commissioner, Inspectors of 1988 would still remain as Inspectors. This
proposal puts the Central Excise officers in an ignominious situation of
working under an officer who is more than 10 years junior to him.
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10.The proposal renders 321, 175 & 68 Inspectors surplus in West Bengal,
Kerala & Tamil Nadu Zones respectively. The proposal reduces the strength
of Superintendents by 36 in Kerala Zone.
11. The proposal does not contain any scheme to do away with the disparity of
Central Excise cadres with Customs. As per this, 1995 batch of
superintendents alone would be promoted while the 2007 batch of
appraisers and 2001 batch of Superintendent (customs) would be promoted.
Though the Board has accepted the fact that the present ratio of promotion
to Assistant Commissioner has to be scrapped and a new mechanism has to
be brought in, the proposal is silent on this. While giving a march over to
Customs cadres, the proposal grossly discounts the fact that more no. of
Central Excise Inspectors/Superintendents is doing Customs works than the
exclusive Customs cadres.
12.As this proposal also takes into account the immediate future requirements
of the Department and as the Board is well aware that the bogey of
stagnation cannot be wiped away with one swell stroke called restructuring,
this proposal should have projected certain means by which upward mobility
of the Group ‘B’ cadres could be maintained. In this regard, the proposal of
this Association regarding curtailment of DR quota to Gr. ‘A’ to 25 % should
have been discussed in detail.
CHANGES DEMANDED
1. One time relaxation should be granted to fill up all the vacancies arising in
the cadre of Assistant Commissioner including consequential vacancies
should be filled up by promotion.
3. In 4 cadre zone- viz. North East, West Bengal, Tamil Nadu & Kerala, no
additional executive Commissionerates have been proposed. Some of these
Commissionerates in these zone at present have a sanctioned strength of
more than 80 Superintendents (the revised strength as per proposal). These
posts have been sanctioned on account of factors like presence of customs
formations, more than 5 Ranges per division etc. These sanctions, which
have been made after collating complete data about workload, should be
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Zone Posts to be
upgraded
Shillong 312
West Bengal 740
Tamil Nadu 572
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Kerala 179
UP/UTHARANCHAL 370
Andhra Pradesh 106
Rajastan 19
Bihar/Jharkhand 35
Total 2243
ALTERNATIVELY
The newly created posts should be distributed among zones on the basis of
stagnation evenly among the zones.
8. Zone specific details of the lagging behind zones are appended as Annexure
C.
Yours faithfully
Encl: Annexures A-C
(KOUSIK ROY)
SECRETARY GENERAL
AICEIA
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ANNEXURE- A
* In these zones after promotion of 2002 batches posts would remain unfilled
for want of qualified candidates
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ANNEXURE B
MINIMUM REQUIRED STRENGTH OF SUPERINTENDENTS IN AN EXECUTIVE
COMMISSIONERATE
9 Legal/Prosn 4
10 Review Cell 5
11 Adjudication 3 1
12 Audit * 4 1
13 Data processing cell 2
Total 35 9
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ANNEXURE C
TAMILNADU REGION
Though the norms adopted in this proposal for creation of Service Tax
commissionerate is revenue of Rs. 3000 crore (PLA+CENVAT) and assessee base of
17500, a ST Commissionertae was sanctioned in Chandigarh purely on assessee
base. The Chennai City area has a present assessee base of 71000 which calls for
creation of a minimum of 3 ST Commissionerates. Similarly there are 26000 ST
assessees in Coimbatore Commissionerate which calls for creation of a ST
Commissionerate in Coimbatore.
This region as per the proposal would have 11 CE/ST Commissionerates and hence
in line with the demand no. 7 of the submission, one more Audit Commissionerate
has to be created.
Para 5.1 (iv) of the proposal deals with the Chennai Customs (P) Zone wherein it is
mentioned that the Tuticorin and Tiruchirapally Commissionerates were intitially
created as Customs Preventive Commissionerates which is factually wrong.
Tiruchirappally Customs (Preventive) Commissionerate was in existence since
1997. Tuticorin Commissionerate was carved out of Tiruchirapalli Preventive
Commissionerate in November 2002 and though defined as Tuticorin Preventive
Commissionerate, it only attends assessment and clearance of import/export
goods and is functioning as one of the major Ports in India. As such the Tuticorin
Customs House Commissionerate fulfils the norms for an Integrated Customs
Commissionerate by handling the required number of documents viz., 150000 BEs
& SBs. It is an irrefutable fact that the Tiruchirapalli Customs (Preventive)
Commissionerate alone is attending the preventive work by manning 17 Preventive
formations covering the entire of 950 kms of coastal stretch of Tamilnadu and
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The other Customs formations coming under the jurisdiction of the Trichy Customs
(Preventive) Commissionerate are as follows.,
• Trichy International Airport
• Coimbatore International Airport
• Air Cargo Complex at Coimbatore
• Five ICDs & one CFS at Coimbatore/Tiruppur
• Minor Ports at Karaikal, Custom Houses at Nagapattinam, Pondicherry &
Cuddalore
• ICDs at Pondicherry, Karasoor, Arakkonam & Karur
• Madurai Airport (to be notified as International Airport shortly)
• Air Cargo Complex at Trichy (to be notified shortly and proposed to
commence working from 01.12.2010)
• Ferry service to Thalaimannar from Rameswaram ( to be started shortly)
• Handling Customs Private Bonded Warehouses
Going by the principle adopted in the reorganisation of the Amirtsar Customs (P)
Commissionerate by bifurcating and creating Customs Commissionerate at
Ludhiana which may exercise control over all revenue generating formations
located in the State of Punjab, the revenue functions of Tiruchirapally Customs (P)
Commisionertae may be delinked and a new integrated Customs Commissionerate
may be created and the present Tiruchirapally Customs (P) Commissionerate may
be retained with on focus Customs Preventive work.
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In the Customs side no new Commissionerate has been proposed for this region,
though a separate Customs Preventive Commissionerate in Siliguri for North Bengal
and Sikkim area has been proposed both by the Chief Commissioner as well as the
Study Group constituted for review of the organizational structure of Customs
formation.
These LCS are organized under Two Customs Divisions, Siliguri & Naxalbhari
Customs Divisions spread over the districts of Jalpaiguri, Coochbehar, North
Dhinajpur, Darjeeling and the entire state of Sikkim. Apart from this a
Preventive & Intelligence Unit having jurisdiction over these two Divisions also
exist.
Besides these Hilli LCS and Mahadipur LCS under Malda Customs Division of
Customs (P) Commissionerate West Bengal also exist in this region.
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It is proposed to
• Creation of one more Central Excise Commissionerate.
• Creation of Service Tax Commissionerate
• Specific sanctioned strength for Guwahati Commisionertae
• Creation of another Customs (P) Commissionerate.
The present proposal lacks proper appreciation of the ground realities and
has ignored the actual working environment, workload, geographical (total
2,55,168 Sq. Km. Land area) and political condition and acute nature of the
stagnation that exists in the cadres of Inspectors in the Shillong zone. The absence
of any specific proposal for removal of acute stagnation and regional disparity in
promotion, the proposal for continuation with the existing three Central Excise
and Service Tax Commissionerate and one Customs Preventive Commissionerate
reflects the step motherly treatment meted out to the fraternity of Inspector of
central excise & Customs of Shillong zone consisting of whole North Eastern zone
in general.
The assessee-base of Shillong Zone is 1466 nos. i.e. 488.66 per Commissionerate
as on 31-03-2010. The projected assessee-base of the zone for 2010-11 is 1613
nos. whereas in Bhubaneshwar Zone assessee-base is 1145 nos. i.e. 381.66 per
Commissionerate. In Ranchi (Patna) CE Zone assessee-base is 1801 nos. i.e. 360.20
per Commissionerate is proposed. Further, the aspect of additional work load,
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On service tax side, the projected revenue collection of the Shillong zone for
2010-11 is estimated to be 423 crores from around 14,000 (expected to grow
substantially) assessees . Considering the scattered location of the assessee over
a vast geographical area (2,55,168 Sq.Km.) under the seven states of the
region and the imminent prospect of growth in the infrastructure and
industrial sector Propelled by the look east -policy of the Govt. of
India and the norms recommended by the study group-I at Sl. No. 1A(iii) of
chapter 10, at least 2 (two) exclusive Service Tax Commissionerate for the
zone needs to be created.
KERALA
Proposed to
• Create additional sanction equivalent to the strength of a ST
Commissionerate.
• Augment staff strength for Customs formations under Central Excise
In respect of Kerala Zone, the study group of DOPM had conducted comprehensive
study of the working of the Ranges in Kerala as recently as in 2006 and re-
organized the then existing 114 Ranges in to 88 Ranges from January 2007, after
considering all aspects like geographical reach, assessee convenience etc.
Applying the ratio of 1 : 25 in respect of 1 commissionerate to 25 Ranges, needs to
be modified in respect of Zones like Kerala, where industrial units and service
providers are distributed across the states unlike in cities like Mumbai, Delhi,
Chennai. Besides, the operational control of a large number of 100% EOUs has now
been entrusted with Central Excise with effect from 01.08.2010. Further, the
sanctioned strength of Inspectors and Superintendents at Karipur and Trivandrum
International Airports which have 23343 flights with international passengers
numbering 26,78,236, is far less as compared to other international airports. Shift
system has been made operational in Karipur Airport from 2009 without any
additional sanction and by diverting posts from branches of Headquarters office of
Calicut Commissionerate. The Service Tax assessee base in Kerala is projected to
grow to 27095. Kerala being a thickly populated state, the whole state in fact
could be treated as a metro and hence city based asseessee norms for Service Tax
generally adopted cannot be made applicable to Kerala. This assessee base, had it
been in a city would have qualified for a separate Commissionerate and hence in
the special circumstances of Kerala, the staff strength required for a service tax
commissionerate may be added to the strength of the zone, apart from retaining
the present sanction and augmenting strength for Airports and other Customs
work.
RAJASTAN REGION
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organized that their main focus remains Customs Preventive work and it
does not get diluted by any revenue collection related functions.”
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ANDHRA PRADESH
In line with demand no. 6 of the submission and the norms adopted for creation of
Chandigarh ST Commissionerate two ST Commissionerates should be created in
Hyderabad Zones instead of one that 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 hence
Hyderabad Zones requires at least two exclusive Service Tax Commissionerates
instead of one for effective implementation of Service Tax Law and augmentation
of service tax revenue.
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