F. No. AICEIA/GST/2017/4 Date:24.01.2017
To
Sh.
Arun Jaitley,
Union
Minister of Finance,
&
Chairman,
GST
Council, New Delhi.
Sir,
Subject: GST the biggest revolution
in Indirect Tax Administration – suggestions reg .
At very onset , we the
Inspectors’ of the Central Excise put it straight before your good office that
entire Cadre is apprehensive yet appreciative and ready for being part of the
biggest ever revolution in the Indirect Tax Administration of the Country.
A tax administration, we
understand, is as good as it reflects on the ground. It is at the ‘cutting
edge’ level, the administration is seen and assessed by the very citizen/
taxpayers. The day to day provision of service or lack of it determines how
government will be perceived. The surveys made by the independent agencies
acknowledge the fact that the lower executive formation of Central Board of Excise
& Customs are working with positive attitude .
In this long walk to GST
regime, we tried to submit our views & concerns for smooth transition
several times through our CBEC administration, but every time the ground level
sentiments were diverted with the comment that everything is in liquid state
and unless it takes some shape it is not possible to talk on administrative
part.
After the 9th
meeting of the GST Council on 16.01.2017, which placed the GST implementation
in an advanced stage, we find it as our moral responsibility to put before you
the aspects which need consideration while implementing GST. For convenience
these aspects are classified in following three categories:-
a) Issues related to the
Assessees: - Entire Tax Administration is based on the entities which are being
assessed. The decision dividing the Taxpayers’ base in asymmetric cross
sections both vertically as well as horizontally creates confusion and
inconvenience among the Taxpayers, who expected GST to provide a simplified Tax
compliance mechanism. Though actual parameters to effect such distribution is
yet to be divulged, the business entities are anxious, with multi-location
units fearing the fact that their one business vertical
may fall under Central Control whereas the other may fall under State Control,
due to this random distribution.
b)
Issues related to the Union of India: - We are proud to have the unique Federal
Structure, where co-existence and togetherness is the key. The very purpose of
GST implementation in our Country was to provide a better Fiscal Health to the Union and States as the unified system will minimize the
revenue leakage.
There is an impression in
general that this very purpose was lost midway due to conflict on control
between the Central & the State Governments.
Sir, it is felt that in the
quest to control, the GST Council missed the elementary point of Development
Economics, where division of land reduces its productivity while division of
labour increases it. If the duties
and responsibilities of Tax Administration are divided between the Centre and
States instead of Taxpayers
base the administration will be more cohesive and firm. Even this cross
administration will minimize the chances
of Revenue Leakage.
In the Global Scenario, the
economic health of the country is the strongest parameter of gradation. For
making India centre of the world, we need a strong Fiscal position which
is possible only when some controls are centralized and major policies don’t
get blocked due to regional aspirations.
c) The Executers of
transition: - The employees of Revenue Departments be it Central or State, are
the primary carrier of transition and the success of the new regime mostly
depends on their contribution. But, non-communications are creating panic among
these parts of Administration regarding their role and position in the new
regime. The Inspectors of Central Excise are the most stagnated Cadre working
under the Government of India and despite this fact they work hard and
discharge their duty with full integrity which results in Revenue Collection
more than targeted. In such a situation if the question of job security comes
even as rumor , it is sufficient to de-motivate and demoralize the Cadre and
adversely affect the transition.
Above points of concerns are
needed to be considered for successful GST implementation. We know that raising
concerns is not our only responsibility; rather suggesting way outs for
consideration also lies on us. As a responsible service association, which
desires success of Government Policies, we propose following points for consideration:-
1) Instead of dividing the
Taxpayers’ Base, functional verticals be divided between the Centre & the
States. It may be done in a manner, where all core verticals like Registration,
Assessment & Dispute Resolution etc. are put under state domain and all
peripheral verticals like Audit & Enforcement, Automation, Taxpayers’
Service & Vigilance and Training etc. are kept with the Central. The
dispute resolution function should be kept with the Centre, as the adjudication
pattern in Commercial Taxes of the states is somewhat different from what we
follow and would be in GST.
2) Apprehension in field
formations as to their role in new regime be taken seriously and requisite policies
may be framed, wherever necessary, in consultation with the staff association
3) There should be parity in
duty, responsibility, position & career prospects of the counterparts of
the Centre and State GST.
4) Inspector of Central Excise should be given with role in
GSTN module.
5) Levy of IGST should be kept under Central Control to
safeguard the federal structure.
Sir, we solicit an early
action to ensure that already agitated, stressed Central workforce are soothed
and also request your good office to give us an opportunity to be heard in
person, so that the above submissions can substantially be placed before you.
Yours
faithfully,
Abhishek Kamal
Secretary General
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