Wednesday, December 30, 2015


All India Civil Accounts Employees Association
Phone No. 23345070, Mob. No. 9868520926, e-mail:-

Central Office: -                                                                                            Address for Communication:-
16-A, Akbar Road Hutments,                                                                                  17/2 – C, P & T Quarters,
New Delhi: - 110011                                                                                                                 Kali Bari Marg,                                                                                                  New Delhi-110001

No: AICAEA/HQ/A-2/2015/3078                                                                                           Dated:  30.12.2015

            Shri M.J. Joseph,
            Controller General of Accounts,
            Ministry of Finance,
            Department of Expenditure,
            Loknayak Bhawan,
            Khan Market,
            New Delhi – 110003

Subject: - Comments of Association on the 7th Pay Commission recommendations.


            I am directed to refer the letter No: - A.11019/25/2011/MF. CGA (A)/AICAEA-HQ/413 dated 09.03.2015 of your office on the above mentioned subject and state that, we have submitted a joint Memorandum to the JS(Pers), Department of Expenditure with the request of granting appropriate replacement pay scales vide our letter No:- AICAEA/HQ/A-42/7thCPC2015/ dated 28.12.2015.

            In this connection, I would like request you to kindly refer the discussion held between us on 11.12.2015 in your chamber and forward our representation with your recommendations to the Implementation Cell constituted by the Government for examining and implementing the 7CPC recommendations.

            We shall be thankful if a copy your recommendation letter is endorsed to this Association for its further necessary action.

Thanking you,
Yours Sincerely,
Enclo: - as above

                                                                                                                                     Secretary General 
All India Civil Accounts Employees Association
Central Headquarters
Phone No. 011-23345070, Mob. No. 9868520926e-mail:-

All India Civil Accounts Employees Association Category-II
Central Headquarters
C/o ZAO, CBDT, 3rd Floor, San Juan Towers,
Old Railway Station Road, Cochin-682018
Mob. No. 09446047688, e-mail:-

Central Office: -                                                                      Address for Communication:-
16-A, Akbar Road Hutments,                                                            17/2 – C, P & T Quarters,
New Delhi: - 110011                                                              Kali Bari Marg,           New Delhi-110001

No: AICAEA/HQ/A-42/7TH CPC2015/Dated: 28.12.2015

                        Smt. Annie George Mathew,
                        Joint Secretary (Pers),
                        Department of Expenditure,
                        Ministry of Finance,
                        Government of India,
                        39-A, North Block,
                        New Delhi -110001

Subject: -Memorandum on the recommendations of the 7th CPC in respect of the employees and officers of Civil Accounts organization – request to grant appropriate replacement pay level –Regarding.

 We on behalf of the above Associations would like to refer your D.O. No. 1-4/2015-E.III (A) dated 21st November 2015 and Controller General of Accounts, Ministry of Finance, Department Expenditure letter No. A.11019/25/2011/MF.CGA(A)/AICAEA-HQ/413 dated 9th December 2015 and submit following few lines on the recommendations of the 7 CPC with regard to pay scales of Accounts Cadres.
So far as common issues are concerned, we endorse the suggestions and demands placed by the National Joint Council of Action vide letter No. NJC/2015/7th CPC dated 10th December 2015 to Cabinet Secretary to the Government of India.
            We also endorse the letter No: JAC/2015/1/ 01 dated 11.12.2015 of the Joint Action Committee of Accounts and Audit Employees and Officers organizations addressed to the Secretary, Department of Expenditure and request that our following submissions may kindly be considered sympathetically leading to rectification of the injustice done to the Accounts and Audit cadres through the Empowered Committee that will look into the recommendations of 7 CPC.
1.     Accounts/Audit Assistant:
The Accounting and Auditing Departments are not administrative offices and in these departments, all items of work are of technical nature. Like administrative offices there is no method of receiving dak/letters and dispatch of those in the Accounts Organization or in any other departments of Accounts and Audit. Instead the existing persons who are designated as LDCs in these departments are basically working in the technical sections where they are handling the Bills, different types of Accounts and Audit related documents, Bank Statements, Cheques/ Demand Drafts/Bankers Cheques, Challans, receipt and payment vouchers, ledgers and Broadsheets etc.  After computerization, their duties have become more complex, sophisticated and important as they are to record those documents electronically, generate tokens and even process them in the computers. Virtually the designated LDCs in the Accounts and Audit Departments are discharging technical responsibilities and performing the duties of Accounts Assistants.
In view of this, we requested the 7th CPC that the cadre of LDC in the Audit and Accounting formations may be re-designated as Accounts/Audit Assistants and recommend for grant of replacement scale of PB-1 Grade Pay Rs.2400. But 7CPC ignored the request and gave no comment on the matter. The C&AG and other Departmental Heads of Organized Accounts have recommended the same in the Memorandums submitted to the 7th CPC.
We therefore request that the LDCs of Accounts and Audit organizations may be granted the level 4pay scale of Table 5.Pay Matrix.
2.     Accountant/ Auditor:
The V CPC distinguished the UDCs (designated as Senior Clerks) in the Ministerial cadre of Railways and assigned higher Pay Scale of 4500-7000 (pre-revised Pay Scale of 1400-2300) on the consideration that in the cadre of Senior Clerks there was an induction (direct entry) of 1/3rd by the graduates whereas UDCs of CSS & other offices were promotees from LDCs who were matriculates only. The said Commission however did not recommend the Pay Scale of 4500-7000 for Auditors/Accountants in which cadre there was induction of graduates to the extent of 50% to 80%.
Government of India took note of this omission of V CPC and upgraded the Pay Scale of Auditors/Accountants to 4500-7000 notionally with effect from 01.01.1996 and actually with effect from 19.02.2003.In Para 7.56 of their Report for other posts in IA&AD, the VI CPC had recommended that,
“The Commission has separately recommended Parity between Secretariat and Non Secretariat Organizations in Chapter 3.1. of the Report which will also extend to other posts in IA&AD.”
The VI CPC, conceding the principle parity between Field and Secretariat office, had given the following existing and revised pay structure in Field Organizations vide Table below Para 3.1.14 of VI CPC Report:
Present Pay Scale Recommended Pay Scale

Pay Band    Grade Pay
Head Clerk/Assistant
Steno Gr II &


PB-2                 4200
The term “Equivalent” invariably meant inclusion of Auditors/Accountants in the field offices of IA&AD and Organized Accounts. This is very lucidly implied from the fact that nowhere else the VI CPC had recommended the revised Pay Band and Grade Pay for Auditors/Accountants.
In the light of these, Auditors/Accountants should have been granted the Grade Pay of 4200 in PB-2 and not Grade Pay of 2800 in PB-1 by the Government which was overlooked.
But the 7CPC has rejected the demand for GP 4200, PB2 to Auditor/Accountant by inventing a new baseless and irrational ground that, applicants who are appointed as Accountant and Auditor in the CGLE examination of SSC which conducts the written examination and interview for recruitments in the grade pay of 4600, 4200 and 2800 appear only written examination and not interview. This proposition of 7 CPC was not only irrelevant but also totally wrong. There was no decision of this nature of the government of India and the pay scale of Accountant was never determined on this basis.  Moreover, the 7CPC had not also taken into account the fact that continuation and further promotion ahead of the post of Accountant/ Auditor for the applicants even after their regular appointment is dependent on the clearing of Departmental Confirmatory Examination by them within a period of two years and in four chances. 7CPC seems to be unaware of the fact that the increments shall be available to the Accountants/Auditors only after qualifying in the Departmental Confirmatory Examination by them.
            We therefore, request that the Accountant/Junior Accountant/ Auditor/ Junior Accounts Assistants (in Railways) may kindly be granted the replacement pay scale of PB 2 GP 4200 i.e. level 6 pay scale of Table 5 in Pay Matrix.
3.     Senior Accountant /Auditor (SA)
7th CPC has examined the parity of Pay scales with Assistance of CSS elaborately in the Chapter relating to Ministry of Defence under Organised Accounts Staff heading in para 11.12.134, 135, 136 and 137. The Commission simply observed that,
“TheCommission, in Chapter 7.1, has already taken a view with regard to pay, level of Assistants of CSS. The recommendation there in settles the parities as have been sought to be established.”
But in the para 11.62.17 the 7CPC contradicted itself by stating that posts belonging to two different services performing distinct functions cannot be treated at per merely for the reason of being in identical pay scales at some point of time and therefore, recommended normal replacement levels for the Senior Auditors/Accountants.
The 7CPC had adopted the most unscientific method to deal with the pay parity issue with the Assistants of Central Secretariat. Assistants of Central Secretariat have been brought down to level 6 in the Pay Matrix and thus settling the parity claims of others. At the same time the Pay protection is allowed to the Assistants already in the G.P. of Rs.4600. This method adopted to negate the claims of pay parity is not at all rational. Disparity is allowed to continue further by way of Pay Protection.

The Senior Accountants/Auditors are claiming higher-grade pay on scientific / historical ground. C&AG and CGA also recommended the higher Grade Pay in their Memorandums to 7th CPC. Appreciating all these facts the Senior Accountants/Auditors / Account Assistants (Railways) should have been granted level 7 in the Pay Matrix by treating the Grade Pay of Rs. 4600 as replacement.
Further, we would like invite your attention to the statement of the 7 CPC that the Government had never granted parity in pay scale to Senior Accountant/ Auditor  is factually wrong and hence totally unacceptable.
As a result of job evaluation done by the Administrative Staff College at Hyderabad at the instance of III CPC in which Auditors/Accountants has edge over Assistants grade (of CSS), a solid justification for grant of Pay Scale of Assistant grade to the Auditor/Accountant post had been laid down.
     As such,  in 1984, Government themselves upgraded the Pay Scale of 80% Auditors in the Pay Scale of Assistant grade (425-800) thereby granting parity in Pay Scales amongst them vide Letter DO No 110141/1/78-EG-I, dated September 21, 1983 accepted the demand for grant of parity – to 80% of Auditor cadre. (Copy enclosed as ANNEXURE -I).
     The IV CPC not only clubbed the posts of Auditors of IA&AD and Central Secretariat Assistants and recommended the pay scale of 1400-2600, but also extended the same pay scale to Accountants in Indian Audit & Accounts Department and Organized Accounts which was implemented by the Government with effect from 01.04.1987 vide OM No F.5 (32)-E.III/86-Pt.II, Ministry of Finance, Deptt of Expenditure date 12th June 1987(Copy enclosed as ANNEXURE - II).
     6CPC argued against disparity in the Pay Scales in the CSS and the field offices and emphatically recommended that-
     “the time has come to grant parity between similarly placed personnel employed in field offices and in the Secretariat” and further that “this parity will need to be absolute till the grade of Assistant” (Para 3.1.3).
     As per para 7.56.8 of their Report, the 6 CPC had observed that because it is recommending merger of pre- revised pay scales of 5500-9000 & 6500-10500 which will automatically place Assistants in Central Secretariat and Senior Auditors/Accountants in an identical pay band and grade pay.
     The Government had implemented the 6 CPC recommendations and granted PB2 Grade Pay of 4200 both to the Assistants of Central Secretariat and the Senior Auditor/Accountants of IA&AD &organized Accounts. But subsequently, the Govt. of India vide DOPT OM No I/I/2008-IC dated 16.11.2009, had granted PB-2 Grade Pay of 4600 to Assistant of Central Secretariat.
     In fact, right from 1984, the Government decisively maintained parity between Central Secretariat Assistants and Sr. Accountants/Auditors till it was disturbed in 1990.Government had again restored parity between these two categories of employees with effect from 01-01-1996 notionally and effectively from 19-02-2003 and this position continued even after implementation of the VI CPC recommendations.  It was disturbed once again on 16th November 2009. Thus it is factually incorrect to say that Government never conceded the demand of parity between the Central Secretariat Assistants and Sr. Accountants/Auditors and no Pay commission recommended for the said parity between the Central Secretariat Assistants and Sr. Accountants/Auditors. This observation of 7CPC contradicts its own analysis and recommendations made in respect to the Defence (Finance) Division vide the Para 11.12. 137. The approach of the 7th CPC to negate the claims of parity by bringing down the pay level of Assistants to 6 in the Pay Matrix instead of granting higher G.P. of Rs. 4600 to Senior Accountants/Auditors is totally not acceptable. Even in such case the disparity will continue due to grant of pay protection given to the Assistants who were already in the G.P. of Rs. 4600. It is requested that the Government reject this negative approach and grant higher pay of Rs. 4600 to Senior Accountants/Auditors in Organised Accounts Departments.
            We therefore, request that the Senior Accountant/ Auditor/Accounts Assistants (in Railways) may kindly be placed in the replacement pay scale of PB 2 GP 4600 i.e. level 7 pay scale of Table 5.Pay Matrix.
4.     Assistant Accounts Officer:-
     The 7 CPC vide para No. 11.12.140 made the following recommendations:
     The Commission is therefore of the view that there is no justification for excluding officers in the Organized Accounting Departments who are at GP 4800 from this dispensation. It therefore recommends that all officers in Organized Accounts cadres (in Indian Audit and Accounts Department, Defence Accounts Department, Indian Civil Accounts Organization, Railways, Post and Telecommunication) who are in GP4800 should be upgraded, on completion of four years’ service to GP 5400(PB-2), viz, Pay level 9, in the pay matrix.”
We therefore, request that this recommendation may kindly be implemented.         

5.     Data Entry Operators & Computer Operators
The recommendations given by 7CPC in paras7.7.21 and 7.7.22 do not fit in Civil Accounts Organization on the ground that the EDP grades are not functionally essential after modernization of Civil  Accounts organization.  LDCs, Accountants, Senior Accountants, and Assistant Accounts Officers are efficiently operating the computerized working pattern all over the organisation without any support of EDP cadres. It is on record that, Accountant and Sr. Accountants are performing the EDP works and the EDP cadres particularly the handful of DEOs available only in two departments of Civil Accounts organization i.e. CBEC and Central Pension Accounting Office are working as Accountants.
It is also on record that one of the DEOs of CPAO was converted as Accountant in the year 2000 and posted as Accountant in one of the Pay and Accounts offices of Ministry of Finance at Nagpur and by now the incumbent has been promoted as Senior Accountant. (Relevant documents are annexed as ANNEXURE -III).

Heads of the Departments of both CBEC and CPAO has suggested for merger of this cadre with the cadre of Accountant. Accordingly the Controller General of Accounts had recommended to 6th CPC for merger of the cadre of DEO with the Cadre of Accountant/ Senior Accountant (Copy enclosed as ANNEXURE -IV).

The Principal Chief Controller of Accounts, CBEC vide letter No.Admn./1 (17)9/DEO/2014-15/911 dated 13.10.2014 addressed to the Controller General of Accounts once again insisted that the DEOs may be converted as Accountant as there would not any separate data entry work in the organization within a short time(Copy enclosed as ANNEXURE -V).

We therefore, request that the Grade-A DEO may be treated as Accountant at the time of prescribing their revised scale and  granted the replacement pay scale of PB 2 GP 4200 i.e. level 6 pay scale of Table 5 in Pay Matrix.

6.     Stenographer, PS And Sr. PS
Secretarial staff of Civil  Accounts Organisation, viz. Sr.PS, Private Secretary, Steno Grade-I (Personal Assistant) and Stenographer Grade-II (Grade ‘D’) are being attached with level of officers in the rank of Addl.Secretary, Joint Secretary and Director and they are doing identical and work of similar nature as that of Secretarial staff working under Addl. Secretary / Joint Secretary / Director level in the Ministry and also that of Secretarial staff working under C&AG  of India (Headquarters). 
The post of secretarial staff attached with Addl. Secretary / Joint Secretary level officers i.e. Principal Chief Controller of Accounts , Chief Controller of Accounts in there of Civil  Accounts Organisation may be designated / re-designated as Principal Private Secretary.
With this, we submit that  secretarial staff working in Civil Accounts Organization may be granted the pay scale at par with Secretarial staff working in the Ministry.

7.     Qualification Pay
               The 7 CPC vide Para8.9.45 recommended following in respect of  additional Pay/increment on passing the SAS examination - while discussing the Qualification pay - to the Railway accounts Staff  in Paras 8.9.43 & 44 respectively :
“Since the allowance is not indexed to DA, it is recommended to raise it by a factor of 2.25. The amount will further rise by 25 percent each time DA crosses 50 percent. The nomenclature should be changed to Railway Accounts Examination Allowance”
This isolated recommendation of clearly conveys that the 7CPC did not study the memorandums submitted by different employees Associations of Accounts and audit organizations thoroughly and this has resulted giving piecemeal recommendations or contradictory recommendations.
The same may please be extended to all wings within Organized Accounts including IA&AD.
Under the scheme of Departmental Examination, the UDCs in organized Accounts and IA&AD used to be placed four stages above the minimum pay on passing the Examination. This Examination was also extended to Lower Division Clerks who were graduates. On passing this Examination, the LDC used to be promoted to the post of UDC (Accountant/ Auditor) with three advance increments. The scheme of grant of these advance increments was withdrawn by the Government and replaced by qualification pay after III CPC.
The qualification Pay is now granted to IA&AD and other organized Accounts organizations including Railway Accounts employees for different examinations. As such there is no mention of it in the 7 CPC report. As done in the case of additional pay/increment on passing SAS examination, the present quantum of Qualification pay on passing Departmental Confirmatory Examination may also be increased by a multiplication factor of 2.25 with further rise of 25% when the DA increase by 50%.
               We therefore, request that the recommendations of 7CPC on granting qualification Pay may kindly be implemented and made applicable to all organized accounts organizations and IA&AD uniformly.
               It would not be out of place to mention that no cadre restructuring Group B and C cadres of Civil Accounts organization has taken place after 1987.
               On behalf of the entirety of employees & officers of Civil  Accounts Organisation, we appeal you to consider the above submissions favorably.
               We shall also request you to kindly give an opportunity for oral deposition to the representatives of the Associations so that they could be able to substantiate and explain the submissions it has made through this Memorandum.
Thanking you in anticipation,

Enclo: as above.

Yours faithfully,

(G.K.NAIR)                                                                                               (V.BHATTACHARJEE)
Secretary General                                                                                                 Secretary General
All India Civil Accounts Employees                                       All India Civil Accounts Employees Association Category II                                                                                                 Association
Staff Side Member, JCM (National Council) 

Copy to Controller General of Accounts, Ministry of Finance Department of Expenditure, Loknayak Bhawan Khan Market, New Delhi with reference to his office letter no.A.11019/25/2011/MF.CGA(A)/AICAEA-HQ/413 dated 9th December 2015

(G.K.NAIR)                                                                                               (V.BHATTACHARJEE)
Secretary General                                                                                                 Secretary General
All India Civil Accounts Employees                                       All India Civil Accounts Employees Association Category II                                                                                                 Association
Staff Side Member, JCM (National Council)  

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