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
