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
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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
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