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M P Vijay Kumar 3
INTRODUCTION
CONTEXT …..
( accounting is accountability )
( accounting is base for tax, governance, credit, investment, sustenance)
• Changing needs of the business and ensure better compliance and governance.
• Less Government and More Governance
• More trust on Auditors by Government for better Governance
• Powerful tool for Auditors to express opinion
29/02/20 M P Vijay Kumar FCA 7
Summary of Changes
Newly Added (Clauses) Modified (Clauses) Retained (Clauses) Deleted (clause)
(7) (7) (7)
(v) 1 (xvi) 4
(vi) 1 (xvii) 1
(vii) 2 (xviii) 1
(viii) 1 (xix) 1
(ix) 6 (xx) 2
(x) 2 (xxi) 1
(xi) 3
Banking company
Financial year commencing on or Every company including a foreign
Insurance company
after 1st April, 2019. company as defined in section
2(42)of the Companies Act,2013. Section 8 company
Consolidated Financial Statements: Gate opened – report on negative remarks in subsidiaries CARO
*Small Company under the Act shall be exempt even if it falls under any other eligible category.
(b) whether the reports of the Internal Auditors for the period under audit were considered by the
statutory auditor; (Newly Added)
Documentation of : • Documentation of
• Concerns raised by the Outgoing Auditor – In the Audit Report, Engagement Acceptance
communication before accepting engagement, discussions / (SA 220)
communication with TCWG (by the outgoing Auditor), etc. (concerns • Initial Risk Assessment and
raised need not be in Audit Report alone). Response to Assessed Risks
• Include specifically in MRL that all material concerns/objections (SA 330)
discussed by the outgoing auditor (other than those mentioned in
KAM para) are shared by the Management/BOD/AC.
• Summary of CARO
Whether there have been any qualifications or adverse remarks Reporting (modified) of all
by the respective auditors in the Companies (Auditor's Report) Companies included in
Order (CARO) reports of the companies included in the Consolidated FS
consolidated financial statements, if yes, indicate the details of • Only Reference to the
the companies and the paragraph numbers of the CARO report Clause/Para Number – no
specific reporting
containing the qualifications or adverse remarks. requirement to evaluate
the impact.
− Aggregate original cost, depreciation or amortisation to date and impairment loss, if any, under individual heads to tally
with the figures shown in books of accounts
− Not possible to specify any single form; depend upon, number of operating locations, systems of controls etc.
− The controls and security measures in the company are such that once finalised, the fixed assets register cannot be
altered
− FA register is in such a form that can be retrieved in a legible form
Maintain adequate documentation evidencing the evaluation of controls that seek to ensure the completeness, accuracy
and inalterability of the register
§ Physical verification is the responsibility of the management: however, the auditor may chose to observe physical
verification
§ FA to be verified at reasonable intervals - factors to be considered include the number of assets, the nature of assets, the
relative value of assets, difficulty in verification, situation and spread of the assets, etc
2
7
Fixed Assets CARO 2016 GN Ref. (2/3)
− Land
− Things attached to the earth or permanently fastened to anything attached to the earth
§ The Order is silent as to what constitutes title deeds . GN provides that the following documents mainly constitute ‘title deeds’
of immovable property :
§ Title deeds-mortgaged, seek confirmation from the lender or verify information online from state records
§ Disclose immovable properties which have been acquired, but the title is in the process of being transferred
2
8
Fixed Assets CARO 2016 GN Ref. (3/3)
§ Where title deeds have been lost, certified copies of documents , details about the FIR and a MR may be
obtained
§ In case of disputes, auditor may consider communicating with the legal counsel
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Clause on Inventory (ii)
(a) whether physical verification of inventory has been conducted at reasonable
Focus Areas
New intervals by the management and whether, in the opinion of the auditor, the
*
coverage and procedure of such verification by the management is • New reporting - on the
appropriate; whether any discrepancies of 10% or more in the aggregate for coverage & process of
each class of inventory were noticed and if so, whether they have been verification (adequacy (in terms
properly dealt with in the books of account; of value), class of inventory,
periodicity, etc.)
(b) whether during any point of time of the year, the company has been • New reporting requirement on
New*
sanctioned working capital limits in excess of five crore rupees, in aggregate, 10% or more deviation if
from banks or financial institutions on the basis of security of current assets; identified
• Review quarterly returns /
whether the quarterly returns or statements filed by the company with such
documents filed with Banks/FI
banks or financial institutions are in agreement with the books of account of
– report if discrepancies noted
the Company, if not, give details; with books: encouraged to
prepare Quarterly FS, get the
same reviewed by auditors
quarterly.
whether during the year the company has made investments in, provided any Focus Areas
guarantee or security or granted any loans or advances in the nature of loans,
secured or unsecured to companies, firms, Limited Liability Partnerships or any • No stipulation regarding the loan
other parties. If so, being given in cash or in kind.
• Examine agreements.
New*
(a) whether during the year the company has provided loans or provided • File Form MBP-4 – if Directors are
advances in the nature of loans, or stood guarantee, or provided security to interested.
• New Requirement – provide
any other entity [not applicable to companies whose principal business is to
details of such balance O/s at B/S
give loans], if so, indicate- date to Subsidiaries, JV ,
Associates and Others
• (A) the aggregate amount during the year, and balance outstanding at the • Check : Schedule of receipt of
balance sheet date with respect to such loans or advances and guarantees principal and interest has been
or security to subsidiaries, joint ventures and associates. stipulated at the time of sanction
• (B) the aggregate amount during the year, and balance outstanding at the and “regular”.
balance sheet date with respect to such loans or advances and guarantees
or security to parties other than subsidiaries, joint ventures and associates.
(b) whether the investments made, guarantees provided, security given and the Focus Areas
terms and conditions of the grant of all loans and advances in the nature of
loans and guarantees provided are not prejudicial to the company’s interest; • Check : Schedule of receipt of
principal and interest has been
(c) in respect of loans and advances in the nature of loans, whether the stipulated at the time of sanction
schedule of repayment of principal and payment of interest has been stipulated and “regular”.
and whether the repayments or receipts are regular;
(d) if the amount is overdue, state the total amount overdue for more than
ninety days, and whether reasonable steps have been taken by the company
for recovery of the principal and interest;
• “Terms and conditions” - primarily include rate of interest, security, terms and period of
repayment and restrictive covenants, if any
• No loan agreement
• Report absence
• disclose the aggregate of the total amount of overdue for more than 90 days in respect of
loans granted to such parties
• Obtain the confirmation of the concerned bank or financial institution as to the status of the
loan account including the overdue position as at the balance sheet date
• Application for restructuring proposals to the lenders, may be in different stages of processing.
Submission of application does not mean that no default has occurred
• Report lender wise the period and amount of all defaults existing at the balance sheet date
irrespective of when those defaults have occurred.
• Disputes between the company and the lender on certain issues relating to repayments - the
auditor should consider the prevailing terms and conditions only
the Reserve Bank of India Act, 1934 and if so, whether the registration • Examine transaction related to
has been obtained. activities covered under RBI Act
New * and directions related to NBFC.
(b) whether the company has conducted any Non-Banking Financial or Housing
• Net owned funds as required
Finance activities without a valid Certificate of Registration (CoR) from the
for the registration as NBFC
Reserve Bank of India as per the Reserve Bank of India Act, 1934;
New* • Report if registration is
(c) whether the company is a Core Investment Company (CIC) as defined in the required under section 45IA of
regulations made by the Reserve Bank of India, if so, whether it continues to the RBI Act and the same is
obtained, if not , the reasons
fulfil the criteria of a CIC, and in case the company is an exempted or
for not obtaining.
unregistered CIC, whether it continues to fulfil such criteria;
New* • Check the products / services /
(d) whether the Group has more than one CIC as part of the Group, if yes,
activities carried out by the
indicate the number of CICs which are part of the Group; Company – check with requisite
criteria/registration as required
by RBI – report if not complied.
• Examine the transactions of the company with relation to the activities covered under the RBI Act and directions
related to the Non-Banking Finance companies
M P Vijay Kumar46
My take on winds of change ?
• Data is connected from the source to the ledger via cloud-based applications. Accounting is morphing
into what economists call "interaction jobs", where technical knowledge is assumed and higher value is
applied to a person's ability to interact with internal and external clients, identify problems, come up
with alternative solutions, determine which are affordable at this point in time and communicate and
influence to deliver an outcome.
• The successful accountants of the future will be strong communicators, possess greater IT skills
combined with strategic vision and they will be devoted to ongoing professional development.
Globalisation is the future of accounting as more and more businesses require real-time
manufacturing and information, mobile marketing and online tools, including the cloud, to expand
their customer base internationally. Thus accounting, auditing and finance professionals with
knowledge of international standards and regulations will thrive.
• ICAI is geared to this reality and 34 overseas chapters of ICAI is a testimony apart from embracing
International accounting and assurance standards. Indian Chartered Accountants, thanks to the
rigorous training and enviable forward looking curriculum, possess right insights and foresight to
overcome challenges and make the best use of the opportunities.
M P Vijay Kumar
Thank You
reachable at ,mpv@icai.org