Is roles and responsibilities letter substitute for RPL?

My academics is pure Science and I am working in IT Services sector in Australia as a Business Analyst. Now, I want to apply for PR [Skilled Independent visa (subclass 189)] under occupation ICT Business Analyst (261111).Based on the ACS gudieline, I have to submit RPL report since my academics is non-ICT. On this forum I came across couple of threads which suggest that submission of RPL report can be avoided my providing role and responsibilities letter issued by HR. Could you please confirm that I can avoid submission of RPL report by providing role and responsibilities letter issued by HR?

You may be required to submit the submit the RPL report to prove you learned some ICT skills during your education.

The skill letters from employers prove your work experience and not education.

Education and work experience are evaluated separately by ACS in same report.

Hi Anil,

Thank you for your reply. Do you mean I need to submit the RPL report to prove the some ICT skills acquired during my ‘work’? You have mentioned ‘education’.

I never had any ICT content in my education.