AIASCT Submits Comprehensive Proposal for Cadre Restructuring to CBIC

 The All India Association of Superintendents of Central Tax (AIASCT) has submitted a comprehensive proposal on Cadre Restructuring to the Central Board of Indirect Taxes and Customs (CBIC).

The proposal has been prepared after examining the present organisational structure, functional requirements of the post-GST administration, cadre strength, workload, career progression and the long-standing stagnation in the executive cadre. The proposal covers the organisational structure of Central GST and Customs, human resource planning, career progression, specialised formations and financial implications.

A Structure Designed for the Post-GST Era

The proposal recognises that GST has fundamentally changed the nature of indirect tax administration. The work has moved from traditional physical verification to digital scrutiny, data analysis, audit, intelligence, investigation and technology-based compliance management.

However, the organisational structure has not changed at the same pace. Many field formations continue to operate under a hierarchy designed for the pre-GST era. AIASCT has therefore proposed a structure that is leaner, field-oriented and function-based.

Primary Executive Circle in Place of the Legacy Range

One of the major proposals is to replace the existing Range structure with an empowered Primary Executive Circle (PEC).

Each PEC is proposed to be headed by an Assistant Commissioner, supported by Superintendents, Inspectors and dedicated ministerial and support staff. The Circle would function as the principal taxpayer interface and handle functions such as registration, return scrutiny, refund processing, recovery, intelligence inputs and taxpayer facilitation.

The proposal envisages scientifically determined taxpayer clusters for each Circle. This is intended to bring decision-making closer to taxpayers and reduce unnecessary movement of files through multiple levels.

More Than 10,000 AC/DC Posts exclusively for Promotion of Group B Executive Cadre officers

The proposal seeks a substantial strengthening of the Group A executive structure.

It proposes 10,900 AC/DC-level posts across CGST field formations, specialised audit, appeals and legal formations, headquarters and Customs formations. The proposal includes 6,500 posts for Primary Executive Circles, 1,200 for specialised audit, 500 for appeals and legal work, 800 for headquarters functions and 1,900 for Customs formations.

The objective is not merely to create additional posts. The proposed posts are linked to specific functions, workload and operational requirements.

Central Tax Service for Meaningful Career Progression

A major component of the proposal is the establishment of a Central Tax Service (CTS).

The CTS is proposed as a structured and self-contained career pathway for the executive cadre. It would provide progression from Inspector and Superintendent to Group A grades through a defined promotional structure.

The proposal envisages the Group A grades of the CTS as a parallel promotional stream, distinct from the existing IRS(C&IT) direct-recruitment stream. The proposed CTS grades would be filled through promotion within the Service.

This is intended to address a major concern of the executive cadre. Many officers spend most of their career in the feeder grades and reach the Assistant Commissioner level very late, or retire without reaching Group A. The proposal seeks to replace this uncertain progression with a structured career path.

1,848 Joint Commissioner-Level Posts for the Promotional Cadre

The financial and structural model proposed by AIASCT specifically provides for 1,848 ADC/JC-level posts under the Central Tax Service.

These posts are proposed as a dedicated promotional channel for the executive cadre. The model also provides 5,150 AC and 5,150 DC posts under the CTS structure.

The proposal therefore seeks to create a clear progression from the field executive level to senior Group A responsibilities, while retaining a separate and focused structure for direct-recruitment officers.

Unified Executive Cadre

AIASCT has also proposed the unification of the historical CGST/Central Excise, Customs Preventive and Examiner streams into a Unified Executive Cadre.

The objective is to provide greater flexibility in manpower deployment, common training and a more balanced career structure. Officers can be trained in areas such as data analytics, financial accounting, investigation, digital forensics and anti-smuggling operations.

Strengthening Customs Formations

The proposal also gives due importance to the Customs wing of CBIC. It proposes additional posts of Assistant Commissioner level across sea ports, air cargo complexes, international airports, ICDs, CFSs, land customs stations and preventive formations. The objective is to strengthen customs clearance, risk-based assessment, trade facilitation, intelligence gathering and anti-smuggling operations in view of growing trade volumes and increasing operational complexity. The proposal envisages more than 1,900 AC-level posts for Customs formations as part of the overall restructuring.

A Proposal Focused on Both Officers and the Department

AIASCT has emphasised that Cadre Restructuring should address both career progression and organisational efficiency.

The proposed measures seek to reduce stagnation, make better use of experienced officers, strengthen field formations, reduce clerical burden on executive officers and align statutory authority with functional responsibility.

The proposal also seeks to strengthen CBIC’s capacity to administer a growing and increasingly digital economy. The objective is to create a responsive organisation capable of effectively implementing ongoing indirect tax reforms, meeting future operational demands and supporting India's economic growth.

Call for Meaningful Stakeholder Consultation

AIASCT had earlier requested that the report of the Working Group constituted by CBIC and the proposal under consideration by DGHRD be shared with the Association. The Association has maintained that wider stakeholder consultation would enable informed and constructive suggestions based on field-level experience.

AIASCT has requested that the proposal be considered in its entirety and that an opportunity for interaction or hearing be provided before finalisation.

The Association remains committed to constructive engagement with CBIC and the Government for a balanced, practical and sustainable Cadre Restructuring framework.

The objective is clear: to build a stronger organisational structure, ensure meaningful career progression for the executive cadre, and create a more capable and future-ready CBIC that can effectively support the country’s economic growth and contribute to nation building.

Covering Letter to CBIC submitting the Proposal  

Click here for Proposal submitted by the AIASCT to CBIC