The All India Conference of Commissioners of Audit was held at New Delhi
on 12-02-2015 under the Chairmanship of Shri S.B. Singh, Member (CX and ST),
Central Board of Excise and Customs. Among others, the Conference was attended by DG,
HRD and DG, Systems. The list of
officers who attended the conference is enclosed as Annexure to these
minutes.
2. The DG Audit extended a warm welcome to
the Member, CBEC and other participants and informed that the conference of
Audit Commissioners has been convened to discuss various issues pertaining to
the Audit Commissionerates. He informed
that DG, HRD and DG, Systems have been specially invited to this conference to
appreciate and address the concerns expressed by the Audit Commissionerates on
lack of infrastructure, insufficient funds, difficulties faced in accessing
ACES/EDW and uploading of Audit Report Utility (ARU). He stated that presentations would be made on
risk based audit selection, performance management, integrated audit, uploading
audit report utility in ACES and accessing data from EDW. He requested the Commissioners to actively
participate in the deliberations to arrive at meaningful solutions on various
issues faced by the newly created Audit Commissionerates.
3. Member (CX and ST), CBEC in his address
highlighted the various initiatives undertaken by the Directorate General of
Audit in the sphere of audit, such as, proposals on replacing the existing
norms of audit selection with a set of new norms based on sound principles of
risk management, integrated audit covering Central Excise, Service Tax and
Customs, theme based audits at all India and Zonal level and uploading of final
audit reports in the Audit Report Utility in ACES. Implementation of these new initiatives would
improve the efficacy of the audit process and outcomes besides optimal
utilisation of available resources.
4. The risk based approach for audit
selection would help the department to target the assessees who are
non-compliant compared to the present practice of selecting the units based on
the taxes paid. Integrated audit was expected to minimise the compliance burden
on the taxpayer. Theme based audits would provide analytical inputs to the
policy makers on specific industry/service sectors.
5. On the difficulties faced in areas like
infrastructure, funds and system related matters, the Member requested the
participants to deliberate on these issues with the DG, HRD and DG, Systems to
find appropriate solutions. The
Commissioners were advised to send the Monthly Performance Reports (MPRs) to
the process owner, i.e. DG, Audit within the time limits specified. The Member desired that the Audit
Commissionerates should effectively handle the tax audit function to improve
the overall compliance, as audit plays a major role in compliance
management.
(Action; DG, Audit/DG,
Systems/DG, HRD/Chief Commissioners / Audit Commissioners)
6. DG,
HRD informed that the issues brought forth by the Commissioners fell in 4 broad
categories namely, infrastructure, computers, vehicles, and administration
(transfer policy). On infrastructure, so
far only 4 proposals have been received from 45 newly created Audit
Commissionerates. Only in one case the proposal could be
forwarded to the Ministry for approval as it was found to be complete and
conforming to the standards prescribed in the Infrastructure Manual. The
remaining 3 cases have been returned to the formations seeking
clarification/amendments. It was
stressed by DG, HRD that unless the proposals were complete and strictly in
conformity with the prescribed procedure, the Ministry would not accord
sanction/approval. It also was stressed
that only concrete, comprehensive and self-contained proposals complying with
instructions contained in the Manual on Infrastructure should be sent to the DG,
HRD for further processing and seeking approval from the Ministry.
7. With regard to the requests received
from the field formations on sanction of funds under RRT, the DG, HRD informed
that sufficient funds were available under RRT and approval would be given for
proposals received in proper format, complete in all respects as per the check
list provided in the Infrastructure Manual.
It was informed that care should be taken in computing the space
requirements in terms of the instructions in force, as IFU had objected to the
space requirement projection based on the sanctioned strength rather than the
working strength. Computerisation was
expected to reduce the space required for storing records, files, etc. and this
may be factored into while forwarding the proposals for hiring/outright
purchase of office space requirements.
8. On the fund requirements under
Information Technology (IT) Head, the DG, HRD informed that an additional
amount of Rs.10 Lacs for each Audit Commissioners could be considered provided
the Commissioners were confident of spending this amount for procuring IT
equipment before the end of this financial year. The Commissioners were advised to ensure that
no amount was left unutilised from this additional fund proposed to be
allocated for each Audit Commissionerate.
9. On the issue of conferring HOD status
to all Audit Commissioners, it was informed that the proposal has already been
forwarded to AD-IV Section of the Ministry and the approval is awaited. The ADG (EMC) HRD clarified the distinction
between the budgetary authority and HOD and informed that henceforth the Chief
Commissioners in the Zone would alone act as budgetary authority to whom the
funds would be allocated from DG, HRD.
The Chief Commissioners in turn would distribute the funds among the
Commissioners in their jurisdiction including the Audit Commissioners to meet
the expenditure under various heads.
10. With regard to allotment of vehicles to
the newly created Audit Commissionerates, the DG, HRD informed that the
proposals received did not contain adequate justification/rationale for further
processing. There was also no uniformity
with regard to the number of vehicles requested by various Commissionerates for
operational use. It was suggested that
standard norms may be evolved with regard to the number of vehicles required for
each Audit Commissionerate (staff cars/operational vehicles) and a
comprehensive proposal may be forwarded to the Directorate for taking up the
matter with Ministry for sanction. The DG,
Audit was requested to send a proposal on the number of vehicles required for
each Audit Commissionerate for operational purposes. In the meanwhile, the Audit Commissioners were
also requested to send proposals for hiring one vehicle under 1% scheme for use
by the Commissioner. The particulars of
condemned vehicles from each formation may be sent to the Directorate for
consolidation and seeking sanction for replacement.
11. On the issue of large number of vacancies
in the cadre of ministerial staff and Inspectors, it was informed that the same
has been notified to the Ministry and proposals have been forwarded to the
Staff Selection Commission for conducting exams. As the recruitment process is likely to take
time, it was informed that the Chief Commissioners should ensure that the
existing staff is equitably distributed among all formations within the zone.
12. It was felt that only experienced
officers or officers with accounting and computer background may be posted to
the Audit Commissionerates. On formulation of a transfer policy for posting
officers to Audit Commissionerates, the DG, Audit was asked to examine the
issue. Inputs may be forwarded to DG, Audit
for detailed examination.
[Action;
DG, Audit/DG, HRD/Chief Commissioners/Commissioners (Audit)]
13. The ADG, Audit Hqrs. made a presentation
on the risk management, proposed new norms for audit selection and Annual Tax
Return (ATR). The existing norm for
audit selection is based on a single criterion i.e. the revenue paid in the
previous financial year with prescribed periodicity for units falling under
different thresholds. It does not
address other significant risks. The yield
is much below compared to the potential which could be harnessed through better
audit selection. Stressing the
importance of striking a balance between the quantum and quality of audit, it
was explained that the number of audits should be calibrated with human
resources available and account should be taken of the risk factors. Advanced planning and robust selection
techniques as envisioned in the EA-2000 methodology should be followed to
improve the quality of audits. Adoption
of effective risk management techniques could help in achieving the optimal
balance between the available manpower and the outcomes through effective
audit. It was informed that the risk
based norms for audit selection have been forwarded to the Board for
consideration and approval. The
highlights of the proposal were explained to the participants.
14. The ADG Hqrs. also explained the
significance of theme based audits proposed to be introduced both at national
and zonal level in the new financial year and the expected role to be played by
the DG, Audit and the Audit Commissionerates.
The presentation also covered the proposal forwarded by the DG, Audit
for introducing an Annual Tax Return for both Central Excise and Service Tax
which could replace the existing annual returns such as ER-4, ER-5, ER-6 and
ER-7 and simplify the monthly/quarterly returns such as ER-1, ER-2 and ER-3 and
ST-3. During the discussions, it was
decided that in view of the likely implementation of GST in the near future,
implementation of such return may not be feasible. However, the format designed by the DG, Audit
could be used by the departmental auditors to reconcile the financial
transactions with the tax returns. The DG,
Audit would circulate the format to all Audit Commissioners for critical
evaluation and adoption.
[Action;
DG, Audit/Chief Commissioners / Commissioners (Audit)]
15. The ADG Audit, Bengaluru Zonal Unit made
a presentation on administrative and legal empowerments governing integrated
audits, performance measurement tools i.e. monthly performance reports (MPRs), audit performance
index (API) and quality assurance reviews (QARs), capacity building and skill
development and Large Taxpayer Unit (LTU) audits. The notifications issued by the Board both
under Central Excise and Service Tax empower the field officers to undertake
integrated audit covering Central Excise, Service Tax and Customs. In Zones where more than one Audit
Commissionerate is operational or in cities where more than one Zone is
created, the Board has delegated the powers to the Principal Chief
Commissioner/Chief Commissioner to assign the registrant to one of the nodal
Audit Commissionerate to conduct integrated audit. Similarly, registrants of a business entity
with a single PAN within the Zone could be audited by a nodal Commissionerate
of Audit designated by the Chief Commissioner based on the guidelines issued by
the Board vide Circular dated 22-09-2014.
The Pr. Chief Commissioners/Chief Commissioners should identify the
multi-locational registrants within the Zone, assessees registered both under
Central Excise and Service Tax within the Zone and ACP clients at the beginning
of the year and assign the audit jurisdiction to one of the nodal
Commissionerate for implementing the Board’s guidelines.
16. On performance measurement, the
presentation highlighted the need for sending the MPRs in a timely manner to
the DG, Audit/Zonal Units. It was informed that 21 out of 45 Audit
Commissionerates have not sent the MPRs so far in spite of specific
instructions issued to send such reports by 15th January in the new
formats. The parameters and their
respective weightage for computing the Audit Performance Index was explained to
the participants and suggestions were invited for possible revision in the
future. The presentation also covered
the shortcomings noticed during the Quality Assurance Reviews and the urgent
need for correcting the same.
17. On capacity building and skill
development it was informed that officers posted to Audit Commissionerate
should be mandatorily trained in audit methodology, financial and cost
accounting and Tally/ERP applications. Selected officers could be trained on
CAAP techniques. Collaborative efforts made by the DG, Audit with NACEN, ICAI,
ICWAI and ICSI for building capacity among the officers posted to Audit
Commissionerate/Zonal Units of the Directorate were highlighted during the
presentation. The importance of creating
two exclusive Audit Commissionerates to audit large taxpayers registered with
the 5 LTUs in the country was highlighted.
The need for coordinated audit of large taxpayers spread across the
length and breadth of the country and the specialised skills required for
auditing large taxpayers was also highlighted.
[Action;
DG, Audit/ DG NACEN/Chief Commissioners /Commissioners (Audit)]
18. The ADG Audit, Mumbai made a presentation
on Audit Report Utility and role of Commissioners in improving the efficiency
of audit. It was mentioned that in the current system, perhaps no meaningful
analysis was being made on audit reports (> 40000) issued every year by
various Commissionerates for analysing compliance on sectoral or jurisdictional
basis. Past compliance record was not
factored into in audit selection. It was stated that digitally capturing of the
final audit reports would help in building comprehensive audit database,
analyse the areas of non-compliance/weak compliance. Such analysis could provide important inputs
to the tax administration and the policy makers. The Audit Report Utility (ARU) developed by
the DG, Audit in association with DG, Systems would help in capturing the final
audit report through an offline mode in the existing ACES module. This Utility would capture audit objections
with their codes raised by officers in various Audit Commissionerates. This centralised repository of information
could be viewed by any officer posted in Audit Commissionerates anywhere in
India. The presentation highlighted the
features of the ARU and underlined the need for uploading all audit reports in
this utility.
19. With regard to the role of Commissioners
posted in Audit Commissionerate, the ADG Audit informed that the Manuals
stipulate that the Commissioners shall convene the MCMs, monitor the planning,
selection, conduct of audits and effective follow-up. The Commissioners are
also required to assess the skill gaps and training needs of auditors and
organise training programmes to bridge such gaps. In view of the creation of exclusive Audit
Commissionerates, it was suggested that apart from the above functions, the
Commissioner should also approve draft audit plans of top 5 assessees in each
Circle, review a few draft plans approved by Addl./Jt. Commissioners to ensure
quality of audit. They should also play
a pro-active role in undertaking CAAP audits.
20. On audit process, the presentation
highlighted the deficiencies noticed in desk review, preparation of audit plan
and working papers. The best practice
followed by the officers in the Mumbai Zone-I (initiated by the Chief
Commissioner) in filling up working papers was highlighted and suggested for
adoption by all Audit Commissioners.
[Action;
DG, Audit/Commissioners (Audit)]
21. A presentation was made by ADG, Systems,
Chennai on uploading of Audit Report Utility and access to ACES for viewing
Central Excise and Service Tax returns. The Audit Commissioners were requested
to ensure that their officers are issued SSO Ids. For
obtaining SSO Ids they should send mail to the Directorate of Systems at si.helpdesk@icegate.gov.in
. The Audit
Commissioners will have to ensure that the officer’s SSO Ids are mapped to one
of the executive Commissionerates falling in their jurisdiction. Once this was done,
Audit Commissioners could request the executive Commissioners to (a) issue
instructions for assigning the role of “auditor” in ACES to the officers posted
in the planning and coordination section of the Audit Commissionerate and (b) assign
privileges of viewing Central Excise and Service Tax registration and returns
information through DGCEI template to the audit officers posted in the Circles.
It was informed by ADG, Systems that DG, Systems may be approached for organizing
trainings to officers posted in planning and coordination section either in
NACEN or at Directorate of Systems, Chennai. A document on working procedure
would be issued for the benefit of all Audit Commissionerates.
[Action;
ADG, Systems, Chennai/Commissioners (Audit)]
22. The Commissioner (DDM and EDW) informed
that the Data Warehouse application is in the form of a portal accessible
through CBEC’s central application interface (http://apps.cbec.gov.in). It is accessible to authorised officers
through their SSO Ids. Outline of various reports in the data warehouse was
explained and it was informed that licenses are being distributed to every
Audit Commissionerate. Commissionerates were requested to nominate officers and
indicate their SSO Ids so that licenses on their behalf can be activated. It
was mentioned that EDW would undertake training of officers, whenever a request
in this regard is received from field formations. A new audit package developed
by the EDW team, which was tailor made based on the requirements specified by
Directorate General of Audit, is available for use. The EDW team provided
details of various reports available in the package such as Assessee Profile,
Commodity / Service Profile, jurisdiction profile, containing top assessees and
top commodities / services in a jurisdiction, common pan assessees etc. A CD
containing the assessee information in respective zones was distributed to each
Audit Commissioner. It is expected that the data provided in the conference to
every Audit Commissioner would act as an impetus for its enhanced use in audit functions.
[Action;
DG, Audit/Commissioners (Audit)]
23. Director, ST, CBEC gave a presentation on the
utility of third party information and sharing of database between CBEC and
CBDT. He gave details of return/registration data of ACES given to CBDT for
reconciliation with data pertaining to TDS and ITR IV, V and VI. The data of
about 1,74, 000 assessees showing income through services provided in ITRs but not depositing Service Tax with the
department was distributed to field formations for necessary action. It was
mentioned that about 20000 verifications were conducted leading to detection of
about Rs. 700 Cr and a recovery of Rs. 334 Cr. The Audit Commissioners
emphasized the usefulness of having third party information for conducting the
audit. It was pointed out that a policy needed to be evolved regarding
dissemination of data received from third party source, action to be taken and
monitoring to be done and results thereof.
[Action;
Central Excise / Service Tax Section of CBEC / DG, Audit/Commissioners (Audit)]
24. The executives from Tally software made a
presentation on “e UPASS”, a new feature in TALLY accounting software for
direct uploading of invoice data to the portal of Karnataka Commercial Tax
department. They demonstrated that direct uploading of invoice information
would obviate the need for separate return preparation and ensure ease of tax
compliance. The executive from WINIDEA made a presentation on latest features
built into their software for audit purposes. The manner in which the software
could be used for CENVAT credit verification and audit of financial transactions
was demonstrated.
In both the presentations, it was envisaged that computer assisted audit
is an important aspect which demands renewed focus from the Audit
Commissioners.
25. Various technical issues relating to
audit raised by the field formations were discussed during the conference. Important technical issues raised and
discussed during the meeting are as follows:
(i) Issue of summons by officers of Audit
Commissionerates
A point was raised whether the
officers posted in Audit Commissionerate could issue summons calling for
documents and record statements, particularly in cases involving suppression,
wilful mis-statement, etc.
It was clarified that officers
posted in Audit Commissionerates could issue summons for the purpose of
obtaining documents. They cannot record
statements, as such activity falls under the domain of investigation. Where recording of statement is considered
necessary, a self-contained note may be forwarded to the jurisdictional
Commissioner for taking necessary action.
(ii) Status of objections confirmed in MCMs
held prior to formation of Audit Commissionerates.
It was clarified that all objections
confirmed in MCMs held prior to 15-10-2014 would be dealt with by the
jurisdictional Commissioners for follow-up action. Audits conducted prior to 15-10-2014 which
were not confirmed in MCMs prior to the said date would be transferred to Audit
Commissionerates for necessary follow-up action.
(iii) Posting
of Director (Cost)/Joint Director (Cost) to Audit Commissionerates
The suggestion was accepted. The Chief Commissioners may be requested to
post the Director/Jt. Director (Cost) to the Audit Commissionerates for
effectively utilising their services in audits.
(iv) Amending
the existing Audit Manuals
Suggestions were made to amend/modify the Audit Manuals in view of the
creation of Audit Commissionerates, changes made with regard to integrated
audit, proposal for revision of norms for audit selection and changes in the
law both under Central Excise and Service Tax
The suggestion was accepted. The
field formations were requested to send their comments/suggestions on the
changes required in the Manual. The DG,
Audit would compile the suggestions and undertake the exercise to revise the
existing manuals in a time bound manner.
(v) Revising the existing norm for computing
the Audit Year (April-March)
Suggestions were made for revising
the existing norm for computing the Audit Year (April-March), in view of the
delay in receipt of audited financial accounts of the assessee (available only
after October every year).
It was informed that the annual
audit plan would be required to be drawn for the period July, 2015 to June,
2016, during the next financial year keeping in mind that the provisional
accounts would have been finalised by 30th June. It was agreed that the existing norm of
reckoning the audit year from April-March is ineffective and this would be
changed to July-June in future. Further
comments, if any, on the above may be forwarded to DG, Audit for examination.
(vi) Issue of Show Cause Notice by
jurisdictional Commissioners
A suggestion was made to transfer
the jurisdiction to issue Show Cause Notice arising on account of audit
objection to the jurisdictional Commissioners.
This was not accepted as the
decision to vest the power to issue SCN to the Audit Commissionerate was taken
by the Board after detailed deliberations on the subject.
(vii)
Revision of Objection Codes and Objection Paras in the Audit Report Utility
Suggestions were made to add more objection codes and objection paras in
the Audit Report Utility.
These were accepted and would be taken care at the time of revision of
the Utility.
[Action;
DG, Audit / Chief Commissioners / Commissioners (Audit)]
26. The DG, Audit thanked Member (CX and ST)
who could find time to attend the conference despite his busy schedule and
additional responsibilities. He also thanked the DG, Systems and DG, HRD for
providing meaningful inputs and addressing the concerns of the field formations. ADG, Hqrs. thanked the Audit Commissioners
and other officers for their participation in the conference. The conference
ended with a note of thanks and appreciation to all the officers of the
Directorate for successfully conducting the first all India Audit Commissioners
conference.
*`*`*`*`*`*`*`*`*`*`*`*`*`*
NAME OF THE OFFICERS WHO ATTENDED THE ALL INDIA CONFERENCE OF AUDIT
COMMISSIONERS HELD ON 12TH FEBRUARY, 2015 AT NEW DELHI
1.
Ms. Neerja Shah - DG (HRD)
2.
Shri P. K.
Mohanty ` - DG (Audit)
3.
Shri Jayant
Misra - DG (Systems)
4.
Ms. Ameeta Suri - ADG, Dte. Gen. of HRD
5.
Shri Deepak Garg - ADG,
(HRD)
6.
Shri Shubchintan - ADG
(HRD)
7.
Shri. Ajay Jain - Commissioner (CX), CBEC
8.
Shri S. M. Tata - Commissioner (ST), CBEC
9.
Shri Vivek
Chaturvedi - Commissioner, DDM and EDW
10. Ms. R Bhagya Devi - ADG, (Systems) Chennai
11. Shri B. Thamar - ADG, Kolkata zonal unit
12. Shri Nagendra Kumar - ADG, Bangalore zonal unit
13. Shri Z. A. Khan - ADG, Ahmedabad zonal unit
14. Shri P. K. Agarwal - ADG, Mumbai zonal unit
15. Shri C. J. Mathews - ADG, Hyderabad zonal unit
16. Shri A. K. Mehra - ADG, Delhi zonal unit
17. Shri L. Satya Srinivas - ADG, Headquarters
18. Shri Charanjit Singh - Commissioner (Audit), Chandigarh
19. Shri R. K. Routray - Commissioner (Audit), Coimbatore
20. Shri G.V.K. Rao - Commissioner (Audit), Hyderabad
21. Shri Rajpal Sharma - Commissioner (Audit), Nagpur Audit-I
22. Shri A.G. Ubale - Commissioner (Audit), Vadodara
Audit-I
23. Shri Ajay Dixit - Commissioner (Audit), Lucknow
24. Ms. Kanu Verma Kumar - Commissioner (Audit), Delhi Audit LTU
25. Ms. P. Hemavathi - Commissioner (Audit), Bhopal Audit-I
26. Shri J.S. Chandrashekhar - Commissioner (Audit), Mysore
27. Ms. Tejasvani P.Kumar - Commissioner (Audit), Ahmedabad
Audit-I
28. Shri Bijoy K. Kar - Commissioner (Audit), Bangalore
29. Shri Uma Shankar - Commissioner (Audit), Ahmedabad
Audit-III
30. Ms. Manoranjan Virk - Commissioner (Audit), Delhi Audit-II
31. Shri G. Panmei - Commissioner (Audit), Shillong
32. Shri Raj Kumar - Commissioner (Audit), Kolkata Audit-I
33. Shri Ganesh Havanur - Commissioner (Audit), Mumbai Audit
LTU
34. Shri Milind Gawai - Commissioner (Audit), Pune Audit-II
35. Dr. Ram Niwas - Commissioner (Audit), Mumbai Audit-II
36. Shri Ravi Selvan - Commissioner (Audit), Vizag
37. Shri S.V. Singh - Commissioner (Audit), Delhi Audit-I
38. Ms. Simmi Jain - Commissioner (Audit), Jaipur Audit
39. Shri U. Niranjan - Commissioner (Audit), Chennai S. Tax
Audit
40. Shri Mahendra Ranga - Commissioner (Audit), Meerut-II
41. Shri M. Mathew Jolly - Commissioner (Audit), Cochin
42. Shri P. K. Sinha - Commissioner (Audit), Raipur
43. Shri Rajeev Kapoor - Commissioner (Audit), Mumbai S. Tax
Audit-II
44. Shri Balbir Singh - Commissioner (Audit), Ahmedabad
Audit-II
45. Shri S. K. Sinha - Commissioner (Audit), Delhi S. Tax
Audit-I
46. Shri J.S. Negi - Commissioner (Audit), Vadodara
Audit-II
47. Shri M.R Reddy - Commissioner (Audit), Mumbai S. Tax
Audit-I
48. Shri Sandeep M. S. Puri - Commissioner (Audit), Mumbai Audit-I
49. Shri A. K. Soni - Commissioner (Audit), Delhi, Audit -
I
50. Shri V.C. Gupta
- Commissioner (Audit), Patna
51. Shri K.M. Ravi Chandran - Commissioner (Audit), Chennai
Audit-II
52. Shri Pranesh Pathak - Commissioner (Audit), Delhi S. Tax
Audit-II
53. Shri Rajendra Singh - Commissioner (Audit), Meerut-I
54. Shri Shiv Kr. Sharma - Commissioner (Audit), Kolkata S. Tax
Audit
55. Shri Vivek Prasad - Commissioner (Audit), Bangalore S.
Tax Audit
56. Shri Kumar Santosh - Commissioner (Audit), Nagpur Audit-II
57. Shri Ashok Mahida - Commissioner (Audit), Bhubaneshwar
58. Shri Akhil Kumar Khatri - Commissioner (Audit), Meerut Audit -
II
59. Shri Manish Kumar Sinha - Director (CX), CBEC
60. Ms. Geeta Chabhra - Advisor (Costs),DGA
61. Shri C .H. Venkat Reddy - Addl. Director, DG Systems Chennai
62. Shri Rajeev Yadav - Director (ST), CBEC
63. Shri Amitesh B. Singh - Addl. Director (Systems), Delhi
64. Ms. Himani Bhayana - US (ST) CBEC
65. Shri Amish Gupta - Addl. Director (HRD)
66. Shri Dheeraj Rastogi - Addl. Commr. ST, Audit - I
67. Shri Hari Shankar - Jt. Director, Headquarters
68. Shri Jayashankar - AD Chennai zonal unit
69. Shri Dutta - Asst. Dir., Headquarters
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