Rattan Dogra
We, the senior most industrialists of the state precisely senior citizens, first of all congratulate your goodself for taking over regime of the state as Chief Minster and thanks the Government for declaring State Industrial Policy as earlier had expired by more than one year and was being extended in piece meals thus creating uncertainty among investors.
The policy by large is attractive as there is increase in Capital Investment Subsidy to units in private areas, increase in amount of Subsidy to large category units between Rs.1.50 to Rs. 3.00 crore (depending upon the location) when previously it was hardly Rs.30 lakhs maximum, increase in amount of subsidy and its rating for DG Set, increase in Quality Control Subsidy, Increase in Pollution Control Equipment Subsidy, entitlement of Interest Rebate subsidy to those units who do not get this subsidy under Central scheme besides Zone-B industry getting additional 2% subject to a maximum limit, allowing interest rebate subsidy for substantial expansion which was otherwise withdrawn by GoI, allowing vertical construction in industry, financing private land development and many other developmental incentives. In ease of doing business scheme the procedures have been streamlined to maximum extend. All these steps shall bear fruit in long run towards industrialization.
Being ex-office bearers of the Association at different levels and having running industrial units for four decades, we take privilege of submitting some suggestions on incentives and they are as under;
In previous industrial policy there were clear cut guidelines for the purchasing departments and the purchase committee without participation of the Representative from Industries and Commerce Department was considered null and void. In case we go to much earlier position it shall be found that there was a deterrent by way of entry by red ink service books for those purchasing officers who violate the purchase policy. The present policy needs incorporation of all such clauses otherwise supply orders shall be floated out-side the state. The previous policy safe guarded the interests of that unit who were even higher than 15%, the departments had to negotiate with such units so that they bring their rates below i.e. upto 15%. (for reference please refer to clause no. 3.7 under head Price/Purchase Preference, Sub Head Explanation which be incorporated in present policy).This clause needs addition in present policy as manufacturing cost of state unit is always higher than those of industrially developed states.
Tender fee has been enhanced five times, it is suggested that fee should be Rs.100.00 per tender as used to exist.
The policy states that a unit should have on-line PCE facility. A micro unit or SSI unit who requires less value PC equipment cannot afford on line monitoring. Such condition can be put for high investment industry.
The sick industry needs revival by way of relief and additional benefits rightly envisaged in rehabilitation program at para 2.15 while in para 2.12.4 it is stated that land to sick units shall be retrieved. There is a contradiction and later condition needs to be deleted.
The allotment committee of land should have representative from Association as member so that land allotment system is transparent and in public domain. Similar yard stick for requirement of land cannot be applied for every activity for the reason that there are some activities where requirement of land is more than the thumb rule of SIDCO/SICOP. Therefore, land requirement be calculated on case to case basis. In addition provision for judicious expansion of the unit be kept in consideration while allotting.
It is normally observed that there is gap between provisional registration and allotment of land by many years. This period is to be taken into account as unit holder has no fault and registration extended proportionately. The unit holder during this period may be allowed to change the line of activity, if he desires so, for the reason that due to delay earlier activity may not be feasible. Fact remains that he is not in a position to enjoy any benefit of the Government during this gap period.
Change of constitution, change of activity, addition of activity and change of name and style by formally registered units is a normal trade practice throughout the country otherwise business may come to halt. In para 2.12.4, later these three have not been incorporated which can mean a future set back to industrial development. It is suggested these three ingredients of the business practices may be incorporated
There is dire necessicity to reconsider land rates. The rates have been enhanced by more than 250%. An educated un-employed youth who would start his industry on loan raised under J&K EDI shall find it difficult to pay Rs.10.00 lakhs for just two kanals out of limited loan Rs. 15 to Rs. 50.00 lakhs. Moreover large number of units who are waiting for allotment of land for years have based their projects on previous land rates may find it difficult to absorb such escalation thus shall have to shelve their projects. The other litmus test is that state did not receive any major investment on previous land rates then how investments on higher rates are expected. Therefore, it is suggested that the increase in the rates may be put on halt for time being.
Ease of doing business order shall positively lighten the entrepreneurs. A slight modification is needed to the extent that instead of getting the affidavit registered from court of law, a self attested document be accepted which is a common practice at Central level too or in maximum the Notary registered document be accepted. Madam, in order to get one document registered a full day gets consumed in the court.
Last but not the least the Government should consider extension of earlier incentive like 5% Interest Rebate on term loan to Technocrats/MBAs, Modernization Incentive, Brand Promotion Incentive and Incentive on Captive generation of power etc.
Yours faithfully
Rattan Dogra, R.P. Sethi, Kanwal Kaul, Ramesh Sethi, Verinder Jain and Kuldip Gupta.
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