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Friday, July 19, 2019

MVC IV Objections


Joint Assessor & Collector/HQ                                                                       15 July 2019
Assessment & Collection Department, SDMC
20TH Floor, E-1 Block
Civic Centre, Minto Road
New Delhi 110002



Objection to fixing of incorrect total weightage value - GK Enclave I & II and
Request for classification in category C


Dear Sir / Madam,

Please refer SDMC Public Notice no. Tax/HQ/SDMC/MVC-IV/2019/D-447 dated 17 Jun 2019, under section 116B (1) inviting Suggestions/Comments/Objections on recommendations for classifications of Colonies/Areas/Localities, Unit Area Values & factors for implementation of Unit Area System in the Municipal Corporation of Delhi.

As per your Matrix, the GK Enclaves I & II total weightage value has been incorrectly fixed at 93, and needs revision and consequent classification of the colony under category ‘C’. Our objections are based on the facts highlighted as under:

Under Level of Services physical infrastructure: Under this category both GK Enclave I & II have been wrongly awarded “A” category.

1.      Water Supply: GK Enclave 1 Colony has two tube wells from which water is drawn and filled in an overhead tank. This facility was created by the cooperative society utilizing contributions from plot holder-members. Our colony gets treated water occasionally, resulting in residents getting underground water for a limited time every day. This matter is being pursued at CEO / Member DJB level, but so far, supply of treated water remains very occasional.

2.      Sewage and Drainage:  Land was allotted to the society in 1970 and as per the rules at that time, a maximum of two dwelling units each were permitted to be built.  Accordingly, more than 45 years ago, the sewage infrastructure was laid down by the Society, exclusively using the funds mobilized from its members, with a capacity appropriate to the needs at that point in time. The infrastructure isalready cracking with the heavy load placed on it due to twice the number of dwelling units having being permitted to be built over the ensuing years, and as a result of this overload, the sewer gutters are constantly overflowing.

3.      Now the load on our sewer lines has further increased because the sewer line of the newly constructed Police Station-cum-Residence complex has also been connected to our colony’s sewer line. This matter, too, is being pursued at CEO / Member DJB level, but so far, no action and/or reply has been received on augmentation of our sewer lines.

4.      In spite of repeated requests, the desilting of our sewer lines and drainshas not been done.

5.      No system exists in our colony for Solid Waste Management, Energy Generation and Supply. The RWA has engaged its own staff for collection, segregation and dumping on solid waste at the municipal dump near the adjoining Pamposh Colony.

Level of services Social infrastructure: Under this category GK Enclave I & II have both been wrongly awarded “A” category.

1.    Both GK Enclave I & II are colonies that are more than 45 years old.  However, facilities like a Community Centre and an RWA Office are not available and have not been developed by any government agency, although provisions exist to develop these out of funds allotted to the MP / MLA of the area.

2.    The residents have to tread considerable distance to reach the market in Greater Kailash Part-1 though grocery shops are accessible at about 700 to a kilometer. Society land in Greater Kailash Enclave-1 was handed over to DDA to develop a Convenient Shopping Centre so that the colony residents could have retail shopping facilities, but the ground reality is that 90% of these shops are being used as Office Complexes, and the DDA / any other government agency has not taken any corrective measures or action against these defaulters.

Economic Status of Residents:  Under this category also, both GK Enclave I & II have been wrongly awarded “A” category.

1.    The original name of GK Enclave I and II is “East Punjab Railways Refugee Rehabilitation House Building Cooperating Housing Society”. Both colonies were developed on the land allotted to the society formed by Railway employeeswho were forced to leave behind home, hearth, and any other possessions and migrate to India during the 1947 India-Pakistan partition. Accordingly, a majority of the residents are retired Government pensioners. Any increase in the property tax amount will be a very big burden on their already limited income.
Metro Marks:Under this category GK Enclave I has been wrongly awarded “5” points.

1.    The distance between the Metro Station & GK Enclave-1 is more than 1000 meters and that too has to be covered on foot, given the available route. Therefore, there should be NIL point instead of 5 points.
General Observations: The Municipal Corporation constituted the fourth Municipal Valuation Committee (MVC) to find ways to increase the revenue of the Municipal Corporation.  As per IV MVC Interim Report, it was suggested to increase the Unit Area Rate of Property Tax. In this report, the Committee linked the increase of unit area proposals rate with the Consumer Price Index.

We have objections on the Proposals, the Methods adopted & the Findings process to increase tax collections on the following grounds:

1.    Municipal Services cannot be attached with the Consumer Price Index because the objective of construction of the Index is limited to being a macroeconomic gauge. This index is not all indicator of each and every cost. Property tax is a tax to fund the expenses for provision of municipal services. In case municipal services are limited or deficient, there will be no case for increase in the price of the same in consonance with rise in the Consumer Price Index. In particular in case of Greater Kailash Enclave-1, certain services like solid waste collection continue to be financed directly by the residents or the water supply is from facilities created by the Cooperative Society would remain a fact irrespective of the increase in CPI. Rather it would deal a double whammy, firstly to brunt of price inflation and secondly to bear increase in property tax too. 

2.    Property tax is leviable on Annual Value of the property, being the rental value it can fetch from year to year. Unit Rate Method is a simplification of computation but should not deviate from the fundament concept of the Annual Value. The prevailing economic conditions do not support any case of increase in the Annual Value particular, as there is insufficiencies of municipal Facilities major source of evasion augmentation of revenue could be plugging the leakage of revenue as a large number of property owners have reportedly escaped the tax net. Therecould be cases of misdeclaration of use with a view to fitting into a lower use factor and hence lower assessment of tax. The burden of deficiency in enforcement should not be put on the honest taxpayers.

3.    Everybody is aware that a large number of houses located in unauthorized colonies have not been paying any Property Tax because it has never been levied on them. Should the authorities wish to continue to spare them the levy, the burden of cost of services provided to them should not fall on the compliant taxpayers.

4.    Chittaranjan Park, which is a similarly situated colony in all respects as the Greater Kailash Enclave I & II, is proposed to be reclassified as “C”. Chittaranjan Park earlier known as East Pakistan Displaced Persons colony, was classified as C for the reason of it being a “refugees” colony. Greater Kailash Enclave I & II are also “refugee” colonies and were earlier known as “East Punjab Railways Refugee Rehabilitation House Building Cooperating Housing Society”.  In fact, unlike our Greater Kailash Enclave-1 colony, Chittaranjan Park is strewn with markets in its planning. Therefore, there is every justification to reclassify this colony as well to category “C”.
While we do hope our submissions will receive due consideration and our prayer granted, we seek an opportunity of personal hearing to put forth our case.

Submitted for your favorable consideration.


Kind regards,


Wg Cdr Virender Sharma (Retd)
Secretary, RWA GK Enclave - 1
New Delhi 110048

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