Land as a Resource for urban finanace- 24-1-23.ppt

JITKUMARGUPTA 28 views 78 slides May 13, 2024
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About This Presentation

PPt tries to brief Land, as a gift of nature, is being grossly misused, abused , manipulated Land is globally used for providing platform for all human driven activities, based on living, working, culture of body/ mind and travel.
Limited availability, coupled with large number of human being...


Slide Content

Unlocking Urban
Wealth-Monetising
Land for Thriving
Urban Local Bodies
Ar. Jit Kumar Gupta
Former Advisor
Town Planning
Punjab Urban Development Authority
E [email protected]

Global Context of Cities

Indian Urbanization
•250 million in 1919
•1210 million in 2011
•1410 million in 2023
•2050-Indian population-1600 mil. --50% in
Urban India.
•Metropolitan Centres -5 (1951)--53 (2011)-
68(2031)
•10 m plus-nil (1951)-3 (2011) -7 (2031)-9
(2051)
•During last 100 years, India witnessed—
--Urbanization level going up by 3 times
---Urban settlements growing merely 4 times
---Total Population multiplying 5 times
--Urban population increasing 15 times and
--Rural population increasing 3.5 times
-India became most populated country on
this planet-2023-1.4 Billion people

Indian Urbanization
•Urban area important because :
Areas of concentration of population,
Providers of large employment.
Areas of large investment.
Housing major infrastructure & services.
Hub around which entire economy gravitates.
Promoters of higher order of productivity
•Major contributors to national wealth/GDP
1950-51 -29% (level of urbanization -17.29%)
1970-71-37% (level of urbanization -19.91%)
1990-91-50% (level of urbanization -25.72%)
2001-02-60% (level of urbanization -27.78%)
2011-12-65% (level of urbanization -31.1%)
10 Largest cities house 8%pop/ produce -15%GDP
53 Metro cities house 13 %pop/ produce 33%GDP
100 Largest cities house 16%pop/produce 43%GDP

URBAN INDIA-2030-Mckinsey Global Inst-
•India Urban Awakening :Building Inclusive Cities -Report-
April, 2010 projected; by 2030:
•590 m -live in Urban India-twice US population
•70% GDP--generated by cities
•80% Revenue --generated by cities
•4 fold increase--in per capita income
•5 times --number by which GDP would multiply
•270 million --net increase in working age group
•70% new jobs(170 mil)--generated in cities
•91 M urban households --will be middle class--up from 22 M
•68 Cities--will be Metropolises-Europe has 35 only
•$ 1.2T capital–needed for projected infrastructure demand
•700-900 million Sqmts-residential/ commercial area
needed annually-a new Chicago to be created
•2.5 b Sqmts roads paved-20times created in last decade
•7400km (350-4ookm/year) of metro needed -20times
created in last decade
•200 million --Rural Indians to benefit-living close to top 70
cities
•75%urban India---to live in bottom segment -earning Rs 80
per day

Indian Urbanisation-II
•Urbanization--determinant /consequence of
economic development.
•Level of Urbanisationand Economic
Development and Positively related
•Urban growth & economic growth --go hand in
hand
•Cities --Engines of economic growth.
•Building productive cities--critical to boosting
rural economy -improved urban consumption
•Urban centers need planned development to;
Attract investment
Provide Employment.
Ensure quality of life.
Promote Sustainability, Productivity,
Livability,
Raising financial Resources
Ignoring Urban Areas
--will jeopardize growth
 -risking employment generation.

•Historical
Context of
•Urban Local
•Bodies

Historical perspective
•-first municipal corporation in India -Madras in 1687
•-1726 -municipal corporations set up in Bombay / Calcutta.
•-1870-Lord Mayo’s resolution an-financial decentralization--paved way for
local self-government.
•Lord Ripon-Resolution --called Magna Carta of LSG—issued by Lord Ripon’s
Government -18th May, 1882.
•Government of India Act 1919, --LSGs operations-transferred to ministers
responsible to new provincial legislatures.-, gave powers to Councils to elect
chairmen/ frame their own budgets.
•Act 1925-made municipalities--population > one lakh-wholly elected
•GOI , Act 1935-introduced provincial autonomy / local self-government
declared as a provincial subject.
•1948-GOI appointed committee-Local Finance Inquiry Committee-to report
on ways/ means for improving financial resources of local bodies.
•1985, --National Commission on Urbanization -appointed by GOI-to
study/suggest mechanism of urban management.
•Constitution (74th Amendment) Act, 1992--called upon strengthening local
self-government in cities / towns
•Third tier of government-Empower ULBs-as Governmnet in its own Right at
local level

•Pattern of
Income and
Expenditure

Land-Urban Context-
•ULBs perpetually in financial distress
•Ever Increasing Gap between
Income/Expenditure
•Major Resources with state/ limited with ULBs
•Need support & empowerment from state &
parastatal agencies-
•Various studies conducted by
experts/Institutions -recommended for
financially empowering ULBS;
•Using various options of
•-Exploring potential of imposing new & higher
taxes
•-Levying fee--for various services provided and
rendered in urban domain
•-Levying User Charges
•-Imposing Tolls
•-Making Optimum use of Land Resource

Expenditure OF ULBS in Haryana state

•Context of
Urban land in
Raising
Resources

Land-Urban Context-
•Land -most valuable gift provided by nature to mankind
•-inelastic in nature --cannot be created / enlarged
•Limited supply of global land
•-71 % planet area under water
•-29 % under Land
•-India 2.42 % ( 32.88 lakh sqkm-29.73 lakh sqkm-landmass)
•--global land mass-1489 lakh sqkm)--17.7 % population(1.4 B)
•-Land –platform for all human activities-.
•-Land play Important role, relevance in
•--planned urban development
•--providing basic amenities of life,
•--creating state of art infrastructures
•-generating valuable resource for local agencies / development
•---12 thFYP-Working Group on Urban Development--
recommended promoting land based fiscal tools-for augmenting
financial resources--for urban infrastructure financing .
•MOUA Report--‘Study of Land Based Fiscal Tools and Practices for
Generating Additional Financial Resources’,--exploring untapped
potential of urban development /context of land for making ULBs self-
reliant financially.

Land & its challenges
•India remains most land-stressed country globallyv-low
land/man ratio
•90 % landholdings--in developing countries not documented,
administered or protected.
•Land --having largest litigations/disputes in Courts
•Urbanization --increasing pressure/demand on land, with
people living in cities expected to grow by 175 per centby
2030.
•Large scale conversion of land--from agriculture-non-
agriculture
•Large expansion of municipal limits
•Large tract of land parcels--lying vacant in urban areas.
•High Degree--of land speculation
•Land administration practices---do not cater for complexity of
land issues with overlapping rights and claims.
•70 per centmore agricultural land --needed to increase in food

Land –Urban Context
•Using land--as basis for raising financial resources,
•-has roots in understanding that ;
•--planned land -commands premium over unplanned land;
•--land with infrastructure --priced higher as compared to
land having no infrastructure;
•--granting planning permission to any land--increases its
value
•--land value in urban market --dictated by permitted
land use -. residential, commercial, industrial etc.
•-Urban Land price--dictated by demand for land for
development
•Based on these minimal principles--various options can be
explored/ leveraged,
•--Promoting and ensuring --Planned development
•--using urban land as fulcrum,
•--for generating/ raising financial resources at local level,
•--for funding urban development
•--enhancing financial status of urban local bodies,

Typologies
of Land Based
Resources

Land Based Tools for Raising Resources
BestOptionstoraiseresources--PromotePlannedDevelopmentand
InvolvePrivateSectoratlocallevel
Chargesforchangeinlanduse
Chargingfeeforscrutiny/sanctioningbuildingplans
LevyingCompoundingFeeonbuiltenvironment
LevyingDevelopmentChargesi.e.Internal&ExternalCharges
LevyingPropertytax
TaxingVacantlands
GrantingAdvertisementRights
LevyingBettermentcharges.
UsingRighttoAirspace
TradingFloorAreaRatio
AdoptingAccommodationReservation
UsingTransferofDevelopmentRights(TDR)
UndertakingTownPlanning/LandPoolingSchemes
•Optimum Utilization of Vacant Government Lands (OUVGL
•Levying Parking Charges

Promoting Planned
Development---
Preparing Master
Plans; Development
plans

Promoting Planned Development
•Globally, planned development is valued -best
land-based option to raise financial resources,
•urban planning known to ;
•-promote Planned development of urban areas
•-Provide basic amenities/services
•--Generate wealth for development agencies
•-makes them self-financing / cash rich
•--helps in levying internal Development Charges
•--Collecting external development charges
•--for funding both hard / soft,
•--internal / external infrastructures in city
•-creation of space for roads and mobility
•-providing open spaces
•-creating space for amenities/services
•-all funded & supported by allottees
•Chandigarh, Gandhinagar, Bhubaneshwar, -
demonstrated planned development –self
financing-generate resources for
cities/authorities/government/people

Granting
Change of
landuse

Change of Land Use
•Price of land intricately related with
•-location/ potential of area/ use of land
•Change of land use -invariably leads to increase in
Urban land prices,
•Change of land use charges levied
•--when land --used for developing agricultural land into--
residential/commercial/ industrial use
•--Power to change of use of land --falling within urban
limits-to vest with ULBs.
•For making operational mechanism would need ,
•--Creating a legal framework
•--Preparing Development Plans
•-Mapping entire Land Resource with usage
•-Defining Conversion charges
•-Creating agency to assess conversion charges
•-Rationalising Land use charges
•. Undue charges lead to non-compliance of
•--law promoting unplanned/illegal development

Levying
Development
Charges-
External/Internal

Levying Development Charges
•DevelopmentIntegralpartofcity/landdevelopment
•Developmentchargesinclude-costofmakingprovisionof;
•-InternalDevelopment
•-ExternalDevelopment
•Servicesinclude;
•-watersupply,sewerage,roadnetwork,storm,waterdrainage,
electricityetc.-networksofservices/amenitiesetc.
•--socialinfrastructure-healthcare,education,community
centres,parksetc.
•--Internaldevelopmentworkscarriedoutwithindefined
area--byPromoter/developer
•-whereascostofexternaldevelopment(citylevelservices)
depositedwithULBs.
•-Entiredevelopment
•--fundedthroughdevelopmentmechanism
•--withoutbeingloadedonlocalbody.
•-Costsultimatelypassedonto
•--plotholdersby
•-makingpartofcostofplotwhichisallottedtothem

Approving and
compounding-
Building Plans

Charges for Approving Building Plans
•Building Plan approval fee
•--one of most vibrant sources of income
•-Ever evolving/devolving
•-never static /never finite
•-depends upon how vigilant is local bodies
•-Cost of approval varies for;
•-residential area,
•--commercial,
•--industrial and
•--institutional areas.
Cost levied for;
-Sanctioned plan
--Superseded pan
--Revised Plan
--completion certificate
---occupation certificate.
•Compounding charges
•-Need properly trained/skilled manpower -
transparency/ rational charges

Charging Compounding Fees
•Compoundingfeechargedfor;
•-regularizingminorviolations-ofbuildingrules.
•-violatorpaydefinedfee
•-forregularizationofconstruction
•-whichotherwiserequiredemolition.
Optiontobeexercisedwithcaution-compounding
violations--whichdon’timpactplanneddevelopment
•Chargingcompoundingfeeneed;
•--welldefined,
•-transparentand
•--rationalpolicy
•-tooptimizereturns
•--otherwiseleadsto—
•--majorviolationofbuildingrules
•--emergenceofcorruptpracticeswithin
organization.
•-IntroductionofselfAssessmentofcompoundingfee

Opting for Land
Scheme Pooling

Land Pooling-Town Planning Scheme
•Town Planning scheme prepared -
•--with final plots distributed to land owners
•--by charging betterment levy
•--from those who have gained by reconstruction of plots
•--by paying compensation to those who lost land.
•Entire process involves
•--pooling of land
•--involving land owners.
•-promoting planned urban development -
•-without acquiring land proposed for development
•-without involving any expenditure on land acquisition
•-Without investing any expenditure on development
•-Self-financing /self-sustaining
•-making available land for roads--free of cost
•-makes available public open spaces -free of cost
•-creating public infrastructure for city
•-making farmers co-parceners in development process
•-Making available land for public purpose to public
authority free from all encumbrances
•-Ahmedabad 76 Kms Ring Road funded / created by
Land pooling process

•Sardar Patel Ring Road--76km longring roadencircling Ahmedabad,
•Toll roadbuilt by --Ahmedabad Urban Development Authority (AUDA).
•Built at a cost of ₹3.55billion,
•opened in 2004-Toll collection 98 crores in year 20-21-
•AUDA demarcated --a region of 1km around road—
•--residential affordable housing zone
•--to improve affordable housing.
•-Greening City -200 hectares of green public space -241 Parks

Optimising
Floor Area Ratio

Tradable Floor Area Ratio
•FAR-determiningbuiltareawhichoveranyland.
•FAR-increasesbuiltspacewithoutchangeinareaofland.
•HigherFAR-morebuiltarea.
•IncreasingFAR-helpsgeneratingmorerevenue
•FAR,globally-amajorinstrument-forintensitydetermining
development/increasingthevalueofland.
•Cities,-where built space in demand --where supply of developed
land remains scarce --FAR effectively used for overcoming
shortage of land / increasing supply of built space.
•Mumbai-demonstrated-strength /potential of generating large
land-based resources.
•In India, potential of FAR used in limited way,
•where maximum FAR placed at 3 or 4,
•in developed countries –FAR 20 --in big metropolises
•Need for rationalizing FAR in few pockets -levying rational
charges for higher FAR
•Need to review FAR on periodic basis -without causing undue
congestion and -overloading infrastructure

Property Tax-
Most Vibrant
Tax

Rationalising Property Tax
•Property tax -most vibrant / effective source of funding urban local bodies.
Mechanism not appropriately utilized.
•Despite lot of reforms -still large leakages in tax base remains
•Reasons for low collection of property tax remains;
•--absence of data base-Constructed area/uses
•-Lack of documenting all properties constructed
•--cumbersome procedures of levying/defining tax;
•--lack of qualified manpower for levying/collecting tax;
•--manual driven approach for levying/ collection;
•--poor maintenances of record,
•-ambiguity of rates,
Encouraging/enabling/empowering Property owners -
-Promoting Self-assessment
---Simplify process of assessment -making area based
-Ease of depositing tax
-incentivizing compliance -in time –rebate-delay-imposing
penalties -Using Technology for creating data base/ levying tax/
collected tax/defaulters/arrears
--Moving from manual driven -technology driven approach
-Mumbai Target property collection tax Estimate -Rs 4500 crores
for 2023-24

Sharing Property
Registration Tax-
Profession Tax


Sharing Property Registration/ Professional
Tax-Most vibrant Revenue Resources
•Mumbai municipal corporation demanded share from
State Government of --
•--50% share of stamp duty /registration charges on
property deeds ;
•--professional tax deducted from employee’s salary.
•-Currently, entire sum collected is retained by state.
•Maharashtra state earns close to Rs9,000 crore
through stamp duty / registration charges annually .
•one third of this, Rs3,000 crore--estimated collection
from Mumbai.
•50% share --will boost civic revenue by Rs1,500
crore.
•BMC hopes --another Rs500 crore byprofessional tax

Taxing &
Optimising
Vacant Land

Taxing Vacant Lands
•Speculationinland--gainedenormouscurrency.
•Process-putonholdlargequantityofservicedurbanland.
•Incertaincities25-35%ofland/17%ofhousingstockremains
vacantforobviousreasons.
•Bringing vacant/unusedlandintourbanmarket/end
speculation/underutilizationofdevelopedland--desirableto;
•--taxowners
•--Taxliability–deterrentforkeepinglandvacant.
TaxingVacantland--Servedualpurpose;
•--beingslandintourbanmarket
•--generateresources,
•--Rationalizinglandmarket.
•-Makelandpricesstable
•-Optimumutilizationofland
•-Optimumutilizationofmunicipalservices
•-ProcessalreadyfollowedbyDevelopmentAuthorities-
•--PUDAimposedextensionfeeon--vacantplotsafterthreeyearsof
allotment--@2%ofcurrentallotmentprice-Extensionfee
•--Resultinginrapidconstructiononplotslyingvacant
•generatinglotofresources
•--Financinginfrastructureforcity

Optimum Utilisation of vacant Municipal Land
•-Lot of valuable municipal land
•-remains unused/misused/abused and
•-locked in inefficient uses in urban areas
•--in shape of institutions/ buildings etc.
•--State of Punjab
•-already launched a scheme called,
•-‘Optimum Utilization of Vacant Government Lands
(OUVGL)’,
•--under which all unused /under-used potential
public lands
•--identified, planned, developed and disposed of for
housing/commercial purposes leading to
•--generating resources
•-for state infrastructure development
•--also brought land into urban market.
•--helped in protecting land from
squatters/encroachers
•-Creating a land bank for municipalities
•-Creating a data bank of Municipal land -for
monitoring/optimum utilisation

Leveraging
Advertisement
Rights

Leveraging Advertisement rights
•Advertisement Rights ;
•-Current era-era of advertisement
•--fetch enormous revenue for ULBs for
•--Creating /maintaining urban infrastructure –
•-By granting right to advertise to private advertisers--
receiving money for such rights
•-including Planning/development/ maintaining
•--Open spaces -Chandigarh
•-Traffic rotaries -roundabouts in cities-Chandigarh
•---local bus stops -Delhi
•--creating dumping yard for collecting waste -Delhi
•-Planting of roadside trees-Ludhiana
•-Street-light poles --used for advertisement.
•Enacting Advertisement Controls Order
•--identifying appropriate spaces for advertisement,
•--mapping sites for advertisement, --specifying -hiring
experts for identifying spaces
•-evaluating potential for strengthening revenue base.
•---allotting through a transparent bidding process,

Charging
Betterment levy

Imposing Betterment levy
Levying betterment charges, has genesis in;
--increase in land values, of private properties--&
Establishment of Improvement Trusts in early
twentieth century &
---development projects undertaken Involves -
sharing part of increase in land values
-benefit accrued/ increase in land values
-Despite forming part of municipal legal framework,
--Betterment charges--not been levied/charged
---lack of will -parastatal agencies/state government
-difficulty in precisely quantifying
-If levied/used logically/ rationally,
-Betterment charges to emerge as potent option to
leverage financial resources in urban areas.

Promoting
Public-Private
Partnership

Public-Private Partnership
-Considering limitations of public sector-
-Resources
--manpower
--expertise
-Technology
--necessary to encourage private sector \--in large-scale
--assembly development / disposal of land
--provision of infrastructures
--supplement efforts of public agencies.
Haryana State taken a lead
--by evolving a comprehensive/ effective framework
-for sanctioning of colonies,
-bringing lot of reputed builders in urban centers
. Haryana model needs replication --for attracting Reputed
developers
-Private developers helped in
--promoting orderly growth
-Generating financial resources
-making available large number of plots
--also for urban poor
---at affordable price

Permitting
Use of Air
Space

Charges for Air Space Rights
•Future Source of generating Revenue
•Example of railways using air space rights
•in Navi Mumbai –helped in
•--generating revenue
•--creating state of art infrastructure /
railway stations
•-creating Space for construction of
offices / commercial spaces,
•--Generating revenue on perpetual basis.
•Accordingly,
•--mechanism of air space rights
•--need to be innovatively used /optimized
•-by ULBs on its land
•-for promoting development
•--to generate resources

Accommodation Reservation
•Concept used in Mumbai/Maharashtra
•Accommodation Reservation
•--land-based concept where
•--owners allowed to use full potential of
construction on land
•--based on defined FAR
•--on portion of land-
•--surrendered to local body for public use.
•--In this mechanism;
•--local body gets access to land/
infrastructure
•--without paying any cost for land
•-made applicable for public infrastructures -
community center/ health center /fire brigade
•whereas owner does not lose
•-entire land and
•-enjoys full FAR on remaining land.

Transfer of Development Rights
•Concept used largely in Maharashtra/Mumbai
•-Under which-Right to Land
•-separated from Right attached to Land
•-Land required for public purpose-roads etc
•-taken over by local body
•-whereas owner given
•-Development Rights on said land
•-in form of a cheque
•--of full potential of land
--FSI-to be used at any other designated place.
--where owner holds land
--owner --Free to exercise -right to sell
--in market--to any other developer.
--TDR can be traded like shares and
--sold to anyone who wishes to use it.

Parking Charges
•Only 10% time –vehicle on move
•Rest 90% time –stationery
•-Parking remains important component of urban
mobility
•Increasing vehicles-create problem of parking
•Institutional/ commercial areas faces problem
•Charging Parking fee –another source of income
•Need for rationalizing parking charges
•-Most visited place-with less parking space -
need higher parking charges
•-Parking fee charged based on -parking time /
class of vehicle parked /place of parking/time of
parking-peak/non-peak hours
•-Creating dedicated spaces for parking during
working hours/ near housing in off-office hour
•Creating an app –for availability of parking-

Levying User
Charges-SW
Collection; Charging
higher rate for higher
consumptuion

74th
Constitutional
Amendment
Act, 1972

74 CAA-Preamble
•In many States; ULBs become weak / ineffective on account of
•--failure to hold regular elections,
•-prolonged supersessions and
•--inadequate devolution of powers / functions.
As a result,
-Urban Local Bodies not able to perform effectively
-as democratic units of self-government.
Accordingly following provisions --Urban Local Bodies
incorporated in Constitution for-
(i) putting on firmer footing relationship between State
Government & ULBs –
(a) functions and taxation powers;
(b) arrangements for revenue sharing;
(ii) Ensuring regular conduct of elections;
(iii) ensuring timely elections in the case of supersession; and
(iv) providing adequate representation for the weaker sections like
Scheduled Castes, Scheduled Tribes and women.

74 CAA-Finanacial resources
•243X..-
•Legislature may, by law,-
•(a) Authorise a Municipality to
•-levy, -collect and --appropriate --such taxes, duties, tolls / fees in
accordance with such procedure/subject to such limits;
•(b) Assign to a Municipality such -taxes, -duties,
•-tolls and -fees levied and-collected by State Government for
such purposes & subject to such conditions and limits;
•c) provide for Grants-in-aid --to Municipalities --from
Consolidated Fund of the State; and
•(d) provide for constitution of such Funds--for crediting all
moneys received, respectively, by or on behalf of the
Municipalities and also for the withdrawal of such moneys
therefrom. as may be specified in the law.

74 CAA-Finance Commission
•243Y..-(1) Constitution of a State Finance Commission
•Finance Commission shall review financial position of
Municipalities & make recommendations to
•-(a) Principles which should govern-
•(i) distribution between State /Municipalities of net
proceeds of --taxes, duties, tolls fees-leviable by State,
divided/ allocation between Municipalities
•(ii) determination taxes, duties, tolls, fees-assigned/
appropriated by, Municipalities;
•(iii) grants-in-aid to Municipalities from the Consolidated
Fund of the State;
•(b) measures needed to improve --financial position of
Municipalities;
•(c) any other matter referred to Finance Commission --by
Governor in the interests of--sound finance of the
Municipalities

Way Forward

WAY FORWARD….
•Preparing inventory of Urban land--Mapping all
land falling within urban lists
•Creating a data bank of existing buildings--
constructed in city including;
•-Location
•-Plot area
•-number of floors
•-total covered area
•-use of residential/commercial/industrial etc.
•-area under different uses
•-Typology of construction
•-ownership
•-Year of Construction
•-Year of approval
-Mapping all new construction
--ensuring all building constructed legally
-Specifying rational policies/programs for
Property tax/ change of land use/ vacant land
tax/Advertisement charges/compounding fee etc
---Involving communities in planning/development

WAY FORWARD….
•Involving private sector in planned development/
infrastructure development
•Mapping all urban infrastructure.
•Preparing Master Plans/Development Plans for city
•Creating ownership of Master Plans
•Having authority to undertake land pooling scheme
•Rationalizing Building Bye-laws
•Leveraging technology
•Having dedicated department for buildings -mapping,
plan approval, identifying illegal construction
•Levying Parking Charges
•Mapping good urban practices
•Bringing all urban local bodies on same platform
•Promoting research in reinventing land based fiscal
tools
•Exploring potential of Floor Area Ratio
•Creating a land bank
•Creating assets yielding dividends on regular basis
•Using technology-for bringing operational efficiency,
economy, time efficiency, minimizing manpower,
lowering maintenance cost , ensuring quality,
•Sharing part of Property Registration -Stamp Duty

WAY FORWARD….
•In addition to raisin resource and
increasing income
•-urgent need to manage expenditure
intelligently
•Having qualified manpower in the domain
of managing income & expenditure
•Leveraging Technology
•Provide facilities for ease of deposits
•-redressal of complaint
•Involving Communities
•-Bringing efficiency in service delivery
•Centre , State and Local Governments –
must come on same platform to raise
more resources-through efficiency;
transparency; easy levying/collecting;
rationalising charges; avoiding
subjectivity and corrupt practices

THANKS
FOR YOUR
Valuable
TIME