Central Board of Indirect Taxes & Customs: For the IRS, Of the IRS and By the IRS

1. One of the most crucial approaches to improving the public service is to reform the departmental internal functioning. Without improving it, the desired outcome in public service cannot be achieved. The basis of any tax administration is that there must be clear-cut roles, functionalities, and work division among the tax officials (executive cadre) so that the assessment/scrutiny of records, facilitation, investigation, notices, and adjudication can be done in an effective way and in a time-bound manner. But the CGST department severely lacks this fundamental aspect of any tax administration, and all the original revenue-related work is burdened on the shoulders of Group-B officers. Sorry to say, but Indian Revenue Officers indeed have no original revenue-related work in the CGST and C.Excise department.

2. The IRS cadre kept on increasing their luxuries and promotional prospects and compromising the objectives and goals of the organization so that they can rule the organization unquestionably and without performance and learning. The cadre of inspectors, which are also being recruited through a tough competitive examination, have been burdened with almost all the department's work, be it notices, reports, investigation, audit etc. including the exclusive work of quasi-judicial authority viz. adjudication, refund order, review, advance ruling etc. The IRS cadre has become only a signing authority, and we firmly contend that our cadre's contribution in all the applauds received and achievements done by this department is unmatched.

3. Everyone has to prove their worth in any public department with clear-cut functionalities, roles, duties, and responsibilities. The continuous autocratic ruling of the IRS cadre has resulted in a department where most of the higher posts have no actual roles and functionalities and having minimal or no accountability. Almost all the work has been delegated to the Superintendents and inspectors. A newly recruited Assistant Commissioner is supposed to learn the official functioning, interpretation of tax laws, reading and understanding of financial statements, and taking initiatives and responsibilities of his action but, instead of learning and taking the initiative, the IRS cadre officer only shifts all the work and responsibilities to the Superintendents (usually having the experience of almost 15-20 years in the executive cadre of tax administration).  That itself speaks the need for a parallel and assessment-based tax administrative structure similar to SGST and Income Tax for better, prompt, and efficient public service. 

4. For example, Rs. 1 to any amount (whether it is Rs. 100 crores); every Show Cause Notice is initiated by Inspectors and Superintendents posted in Range Office. Then the same is forwarded to the Division office. If SCN is in the competence of JC/ADC, AC will forward it to the Headquarters. After that, Inspector and Superintendent posted in HQ scrutinize the forwarded SCN. It is to point out that the same SCN has already been examined by an Assistant Commissioner, a Superintendent, and an Inspector. If there is any query, they return the Show Cause Notice to the Division Office for clarifications. Further, the Division Office will again send it to the Range Office for clarifications. Indeed, it is not the best and efficient administration. 

5. Therefore, It's high time to adopt the best practice of SGST and Income Tax, i.e., to divide the CGST tax administration into sectors that are headed by Joint/Addl. Commissioner level officers. Moreover, the assessment of taxpayers should be divided among AC/DC/Superintendent on a monetary basis (large/middle /small taxpayers).

6. The hope of the present public-friendly government with the GST is to impart a transparent and hassle-free service to the taxpayers. Therefore it's high time to lift the barrier, which is deliberately created, by not allowing the Group-B cadre to enter the higher level of administration despite having the necessary skills and experience of the tax administration so that the dreams of the present government of transparent and honest tax administration can be achieved. Now, the department is also facing tough competition from the state GST. Therefore, only a solid, motivated team can perform in this competitive atmosphere of imparting quality public service and increasing revenue collection.

7. Because of the severe discrimination prevalent in CBIC, the policy-making related to personnel matters is vastly undemocratic and is dominated by the strong Group-A cadre. Participation in policy-making is wholly denied, resulting in discriminatory Human Resources policy and ultimately compromising the efficiency and quality of public service. The HR policy of Group-B officers is miserable and a complete mess. The same has generated huge frustration and resulted in the wastage of enormous public as well as individual resources on unending innumerable court cases.

8. Such a situation not only adversely affects the morale of the Gr. B officers, but also the efficiency of the department and quality of public service. The absence of sufficient scope for healthy vertical growth on periodical intervals reduces the stake of officers in giving persistent outstanding performance and, thus, can diminish the commitment to the departmental objectives and dilute the adoption of best practices in the indirect tax administration. And this is also a significant cause that the officers are tending towards adopting unhealthy and unethical practices, which create grave consequences for the efficiency and quality of tax administration as a whole.

9. The Association firmly contends that it is not any sheer luck or anything that Group-A officers are getting 7-9 promotions in their career, and Group-B officers are merely getting mostly one or max two promotions in their entire career. The same is a result of continuous & deliberate side-lining of the Group-B cadre in the decision-making of personnel matters by the IRS cadre through lobbying and using their domination. In fact, the Group-B cadre of the CBIC has the most demoralized career in the Central Government, having only 1-2 promotions in their entire career.

10. To continue their unethical rule and the racist attitude towards the Group-B cadre, the DGHRD and CBIC chose to prepare the proposal of Cadre restructuring in an undemocratic way and more focused on saving the inefficient practices and administration of the previous regime and the skewed Human Resource Management of severe discrimination between the cadres of Group-A and Group-B. To not include the representatives of the Inspectors and Superintendents, which are the most prominent cadres and the backbone of this department who also possess the necessary skills and experience in tax administration, clearly reflects the intentions of the IRS Cadre, i.e., to again neglect the most unfortunate cadre of the central government despite the excellent performance.

11. Digitalization has brought some transparency in the system, but public service cannot ignore the involvement of humans. Therefore, an equally effective way to curb corruption and deliver effective public service is to create a motivational system of competition and fair play, i.e., to bring in qualitative reforms.

12. Thus, there is a high need to restructure government machinery to remain current with the times so that it can match with the growing demands of quality, efficient and prompt public services. That would do wonders in revenue collection and for ease of doing business.

     

    PRAYERS

    1. The present proposal is for the IRS, of the IRS, and by the IRS and the most prominent executive cadre of Group-B has already denied any confidence in the same. It also defeats the very purpose of public service and is not in the interest of the department as it eventually breeds inefficiency, frustration, shifting of responsibilities, domination of IRS cadre, side-lining of resources, etc., and so it should not be accepted.

    
    2. Introduction of limited department examination to Group-A service and creating fair opportunities for young, experienced, and talented Group-B officers so that they can shape their career and feel motivated all the time.

    
    3. End of severe discrimination being done between Gr. A and Gr. B cadre by ensuring mandatory participation of Associations of all cadre in policy making of personnel matter viz. Cadre restructuring proposal, work division, AGT policy, infrastructure, and distribution of resources.

    
    4. Proper revenue-related work division among the executive officers from top to bottom. To divide the work parallelly among all the executive officers similar to CBDT & SGST for greater efficiency and do away with arbitrary hierarchy created in the CBIC which has ultimately resulted in shifting of all the responsibilities on the shoulders of Group-B officers and has turned the IRS cadre officers only to a signing authority without any value addition.

    
    5. Proper distribution of official resources for the appropriate functioning of the department and tax administration.

    
    6. Creation of fair promotional opportunities for every cadre so that they remain motivated all the time.