Monday, July 06, 2009

Suggestions submitted to the Admn. on Transfer policy for Customs related postings.

[Recognized by Ministry of Finance vide F.No.B.12017/1/2004-Ad.IV A dated 31.12.07 & 14.1.08]
Representating inspectors of Central Excise Commissionerates Jaipur -I, Jaipur- II & Customs Commissionerate Jodhpur
C.No. - CCEEOA/JPR/ Policy/2009/ Dated 06.07.2009

The Chief Commissioner (Cadre Control),
Customs and Central Excise,
Jaipur Zone,Jaipur

Respected Sir,

Subject;- Transfer policy for Group “B” Gazetted & Non Gazatted, “C” & “D” officers for Customs related postings.

Please refer to your office letter C.No.II-3(18) CCO/JZ/ET/2008/4949 dated 02.07.2009 on the subject cited above. In the matter we have called for the views/suggestions from the members of the Association and after careful consideration this Association requests to include the following point wise suggestions on illustrative list of difficulties forwarded by the directorate in respect of the existing Transfer policy;-.

1. Short tenure in particular charges may act as disincentive for the officers, who want to learn and develop skills in a particular area of tax administration.- The tenure of a particular charge has been fixed with a view to enable the officers to gain experience in all fields of the department. However, there is no area of work in the department which may require special skills. Hence, longer tenure is not required to be prescribed rather the present policy of one year and two year tenure should be continued. Moreover, all fields of work in the department are more or less inter-related and one can perform the task easily without waiting for special skills to develop.

2. Implementation of Transfer policy in Airports/Baggage treating them as sensitive charges may be difficult due to liberalized free allowances: These postings can now be categorized as non-sensitive because they do not fit into the definition of sensitive postings in the present liberalized scenario. In Jaipur Commissionerate, airport posting has already been categorized as non-sensitive.

3. Need for longer posting in specialized charges like Special Intelligence and Investigation Branch (SIIB), Special Intelligence Unit etc. for continuity in investigation:- For the purpose of continuity in investigation taking longer time an officer may be asked to continue for extended period at a particular charge till completion the investigation but in such matters, the said officer should be allowed to devote his full time to such investigation exclusively and he should not be burdened with the other routine work of the charge where he is posted.

4. Frequent change in charges may impact record management adversely: Record management is working according to the system that has developed in the department and longer tenure is not required for record management. Every officer of the department is aware of the practice of record management in various offices/ branches and there has not been any instance of record management having been adversely impacted due to frequent changes of officers. However, Tax Assistants may be posted in each such branch/ office for a fixed tenure of 4-5 years for record management.

5. Alternate posting in Sensitive and Non Sensitive Charges and its impact on administrative efficiency as well as vigilance related measures: For the purpose of achieving administrative efficiency, it is necessary to rotate officers form sensitive to non-sensitive charges and vice-versa. Deviation from this policy should be avoided.

6. Needs of administration to utilized the services of officers who have specialized skills/aptitude may not get requisite attention due to rigid transfer policy: Specialized skills/ aptitude are not required in any filed of the department and it is for this reason that recruitment rules for Group-A/ Group-B officers do not require any specialization. Even the appointments of textile experts have been almost done away with. Every field of work in the department is being effectively and efficiently managed by officers without any specialization. Hence, no deviation from the tenure policy should be made on the ground of specialization. If the department debars recruitment without specialization in respect of a particular post, then in such cases provisions of transfer policy may be relaxed but in cases where both specialists and generalists are working at a particular post without any practical problem in tax administration, no deviation should be made in the case of specialist on the ground that he possesses specialized skills which the department never asked him to compulsorily possess for recruitment to the particular post.

In addition to above, it is also submitted that a separate deputation policy has not yet been incorporated in general transfer policy and therefore, there is lack of uniformity in the matter of considering officers for deputations. Deputation policy should be framed and made part of the general transfer policy, so that all eligible and willing officers may be considered for deputation and no officer is allowed to extend the prescribed tenure of deputation nor the cooling off period is normally relaxed. This will enable uniform exposure to deputation postings to maximum number of willing officers.
Yours Faithfully,

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