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All units are requested to forward their comments on AGT Guidelines by 17.01.2020 in Word format

Sunday, November 24, 2019

Monday, November 11, 2019

Difficulties faced by officers in Audit Commissionerate


ALL INDIA ASSOCIATION OF CENTRAL EXCISE GAZETTED EXECUTIVE OFFICERS: KERALA UNIT
PRESIDENT:  ANTONIO NETTICADAN
Phone : 91- 9495466577
Email : net11ant@gmail.com
GENERAL SECRETARY:  ARUN ZACHARIAH.P
Phone: 91-9447037011
Email: arun_zach@yahoo.com
Address for Communication
ArunZachariah.P
General Secretary
All India Association of Central Excise Gazetted Executive Officers
O/o the Assistant Commissioner of Central Tax & Central Excise,
V Publishers Building, SreenivasaIyer Road
Kottayam 686001

GS/ADMN/2019                                                       Dated. 08.11.2019

To     

The Principal Chief Commissioner of Central Tax, Central Excise & Customs,
I.S. Press Road, Cochin 682018

The Principal Commissioner of Central Tax (Audit)
I.S. Press Road, Cochin 682018


         
Sir,
          Sub:Difficulties faced by officers in Audit Commissionerate with regard to GST
Audit – Reg

1.    The members of this Association working in Audit Commissionerate have reported that they have been given a long list of tax payers with a direction that GST Audit be conducted on those who have filed Annual Return. In this regard the difficulties faced by our members in proceeding with the directions received are brought to your kind notice.

2.    The basic data like address and returns filed can be accessed only through Citrix app. No LAN WAN connectivity has been provided to any of the groups and the officers have also not been mapped to the utility. In respect of LAN Wan connectivity, Annexure B was sent in April 2019 and periodic reminders also made. However, connectivity has not been forthcoming so far. As per the GSTAM, access to the Tax Payer at a Glance (TAG) utility is an essential pre-requisite for desk review and conducting audit. TAG has not yet been made available to officers.

3.    Though unconnected AIOs are available in circles, the numbers would be insufficient when connectivity is provided. Considering the time required to access data from Citrix, at least one AIO per group is to be provided and also, one AIO is to be provided to the Technical Section in each Circle. Also, as many of the AIOs are not in use, the ports will have to be unlocked which may entail a very slight delay. On the question of AIOs, it would be of great assistance to the Audit Tour parties if they are provided with laptops that are configured to access the Citrix application in order that they would be connected to the system even during a visit to the Unit being audited.

4.    The infrastructural facilities in many of the circles as well as headquarters are pathetic. The officers do not have proper and adequate space to sit, nor do they have proper furniture. In many cases, the Officers have had to make do with old furniture that appears to have been discarded from some of the Executive Commissionerate formations at the time of creation of the Audit Commissionerate. The appearance of such a dilapidated office setup is in itself a major drawback especially since GST Audit prescribes that audit can be conducted either at the premises of the Assessee or in our Office. When the Department specifies that the Assessee must provide specified space for Officers who are visiting their premises for the smooth conduct of Audit, the Department itself not providing it’s Officers with adequate facilities smacks of double standards and lowers the esteem of the Officer in the eyes of the trade which in turn has a highly demoralizing effect.

5.    GST and all fresh initiatives of the Department are Technology driven, the latest being Document Identification Number. While the Department is keen to ensure that adequate publicity is given to the trade and public in general that we are technologically savvy and that all and any access to communication is only online, we come up a cropper when it comes to equipping our audit teams with adequate hardware to reflect our motto of being technologically savvy. Our Audit Circles and the groups therein must hence be equipped with sufficient number of computers/ laptops and printers so that they being the face of the Department, they present the image that the Department wishes to convey. As the Audit teams are mobile, they should also be equipped with necessary telephone facility so as to avoid the use of personal phones to communicate with the taxpayers.

6.    Since the processes in GST Audit are all intended to be online, it would be in the interest of the Department that all the officers in the Audit Commissionerate be trained in GST Audit and online requirements prior to the commencement of GST Audit. As this has not been carried out till date and further, as the required modules are still to be made operational, it is opined that the GST Audit scheduled to be carried out now may be deferred till all requirements are in place. Such a step we believe would give adequate breathing space to both the Department as well as Officers to get accustomed toprocess and will result in the smooth conduct of Audit as compared to the rather tardy roll out of various modules of GST as a result of which Officers in the field are a frustrated lot.

7.    Further, as the relevant date for the submission of the Annual Return for 2017-18 is 30th November, 2019, the normal period of limitation would expire only on 30.11.2022 and hence it is suggested that the start of GST Audit can be deferred to the April 2020. As Audit proceeds on specific timelines, rushing into a system which is still not in place without adequate infrastructure, manpower and training could result in lapses for which as is wont the Audit Officer would be held responsible. It is hence requested that the issues highlighted by the Association be attended to on a priority basis so that our members are not held responsible with reference to any delay in commencing and completing the audit in the absence of required infra structure and facilities.

         
                                                                             Yours faithfully

                                                                             ARUN ZACHARIAH.P
                                                                             GENERAL SECRETARY

CEC Members



CEC Members:        

                                                S/Shri.
1.     TVM Hqrs                                                 (i)      Toms John
2.                                                                       (ii)      Raju Joseph
3.     TVM North DVN                                                Roy Jose
4.     TVM South DVN                                                Rajendran Nair
5.     Kollam                                                                 S.Ajithkumar
6.     Pathanamthitta                                                     Radhakrishnan
7.     Alappuzha
8.     Kottayam                                                             Ramesh Panicer
9.     TVM Airport                                                       Jayaraj
10. ACC, TVM and UB                                            Deepu Divakaran
11. Kochi Hqrs                                                   (i)   Thara Divakar
12.                                                                      (ii)   Tinus Mathai
13. EKM DVN                                                          Shobitha Bhaskaran
14. Kakkanad DVN                                                   Jayasree
15. Aluva DVN                                                         N.Jayaprakash
16. Perumbavoor
17. Idukki DVN                                                        Marykutty Chacko
18. Chalakudy DVN                                                 R.Sajith kumar
19. Thrissur Bjju Jacob
20. CLT Hqrs/DGGI                                            (i)  K.V.Anand
21.                                                                        (ii) Manojkumar V.
22. Palakkad                                                              H.Ramakrishnan
23. Malappuram                                                        K.Shanavaz
24. CLT Rural/Audit                                                 P G. Vinaya Kumar
25. CLT Urban                                                          G.Rejith
26. Kannur                                                                V.Madhavan
27. AP CLT                                                               K P Manoj /  Gokuldas
28. ACC CLT                                                            K.P.Ramdas
29. Audit Circle, CHN                                              N P Padmakumar
30. CCP Hqrs                                                            K.Raeev
31. DGGI                                                                  Jayaraj
32. Audit Circle, TVM                                             Sugunan
33. CCP DVN, TVM                                                Chitra C.R.
Special Invitees:                                                         1. Joju Mampilly
                                                                                    2.Vinod Kumar V.V.