Additional Ques Audit May 24
Additional Ques Audit May 24
Auditing &
Professional Ethics
Additional
Questions for
May 2024
BY CA Sanidhya Saraf
3 Group Audit -
Answer:
As per SQC 1 engagement quality control reviewer can be a partner, other person in the firm
(member of ICAI), suitably qualified external person, or a team made up of such individuals,
with sufficient and appropriate experience and authority to objectively evaluate, before the
report is issued, the significant judgments the engagement team made and the conclusions they
reached in formulating the report.
It also states that the engagement quality control reviewer for an audit of the financial
statements of a listed entity is an individual with sufficient and appropriate experience and
authority to act as an audit engagement partner on audits of financial statements of listed
entities.
In addition, the work of EQCR involves objective evaluation of the significant judgments made
by the engagement team and ensuring that the conclusions reached by the team in formulating
audit report are appropriate. It is necessary for EQCR to have the requisite technical expertise
and experience to enable her to perform the assigned role of evaluating the work of engagement
team so that any possible misstatement can be avoided. Without ensuring the appropriate
technical expertise and experience, the whole purpose of EQCR is defeated. Therefore, it was
not appropriate for her to accept appointment as ECQR for listed entity.
Further, SA 220 states that the engagement quality control reviewer shall document, for the
audit engagement reviewed, that the procedures required by the firm’s policies on engagement
quality control review have been performed. It also states that it shall also be documented that
the reviewer is not aware of any unresolved matters that would cause the reviewer to believe
that the significant judgments the engagement team made and the conclusions they reached
were not appropriate.
In the given situation, CA Ragini is offered an appointment to act as Engagement Quality
Control Reviewer (EQCR) for the audit of the financial year 2022-23 of XPM Limited, a listed
company operating from a small town. She has accepted the appointment and performed the
Question 1 SA 330
While conducting a statutory audit of “Hope Solutions Limited”, CA Y has assessed the risk
of material misstatement to be low at the financial statement level and at the assertion level due
to a stable, established and relatively less risky business and extremely satisfactory internal
controls operating in the company. However, despite the low assessed risk of material
misstatement, he chooses to send external confirmation requests to third parties for
confirmation of certain material contracts entered into with them by the company. By doing
so, he intends to obtain evidence regarding certain assertions contained in the financial
statements of the company. Do you think his approach is in accordance with Standards on
Auditing? Justify your answer with reasons. (Nov 2023 MTP 2)
Answer:
SA 330 states that irrespective of the assessed risk of material misstatement, the auditor shall
design and perform substantive procedures for each material class of transactions, account
balance and disclosure. In the given situation, the auditor has assessed the risk of material
misstatement to be low. However, despite such assessment, substantive procedures have to be
performed.
SA 330 further states that the auditor shall consider whether external confirmation procedures
are to be performed as substantive audit procedures. External confirmation procedures
frequently are relevant when addressing assertions associated with account balances and their
elements but need not be restricted to these items. For example, the auditor may request
external confirmation of the terms of agreements, contracts, or transactions between an entity
and other parties.
Despite the low assessed risk of material misstatement, substantive procedures have to be
performed due to the following reasons: -
(i) The auditor’s assessment of risk is judgmental and so may not identify all risks of
material misstatement and
(ii) there are inherent limitations to internal control, including management override.
It is also in accordance with the spirit of professional skepticism. Therefore, as discussed above,
the approach of CA Y is in accordance with Standards on Auditing.
Question 2
Mr. Rishabh, in the course of audit of PQ Limited, wants to perform external confirmation
procedures to obtain audit evidence. Guide Mr. Rishabh, listing out the factors that may assist
him in determining whether external confirmation procedures are to be performed as
substantive audit procedures. (Nov 2023 MTP 1)
Answer:
Factors that may assist Mr. Rishabh, the auditor in determining whether external
confirmation procedures are to be performed as substantive audit procedures include:
(i) The confirming party’s knowledge of the subject matter – responses may be more
reliable if provided by a person at the confirming party who has the requisite knowledge about
the information being confirmed.
(ii) The ability or willingness of the intended confirming party to respond – for example,
the confirming party:
- May not accept responsibility for responding to a confirmation request;
- May consider responding too costly or time consuming;
- May have concerns about the potential legal liability resulting from responding;
- May account for transactions in different currencies; or
- May operate in an environment where responding to confirmation requests is not a
significant aspect of day-to-day operations.
Answer:
As per SA 700 “Forming an Opinion and Reporting on Financial Statements”, if supplementary
information that is not required by the applicable financial reporting framework is presented
with the audited financial statements, the auditor shall evaluate whether, in the auditor’s
professional judgment, supplementary information is nevertheless an integral part of the
financial statements due to its nature or how it is presented. When it is an integral part of the
financial statements, the supplementary information shall be covered by the auditor’s opinion.
If supplementary information that is not required by the applicable financial reporting
framework is not considered an integral part of the audited financial statements, the auditor
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shall evaluate whether such supplementary information is presented in a way that sufficiently
and clearly differentiates it from the audited financial statements. If this is not the case, then
the auditor shall ask management to change how the unaudited supplementary information is
presented. If management refuses to do so, the auditor shall identify the unaudited
supplementary information and explain in the auditor’s report that such supplementary
information has not been audited.
The auditor’s evaluation of whether unaudited supplementary information is presented in a
manner that could be construed as being covered by the auditor’s opinion includes, for
example, where that information is presented in relation to the financial statements and any
audited supplementary information and whether it is clearly labelled as “unaudited.”
In the current case, the Statement of Average Revenue Per Booking (ARPB) and Comparative
is unaudited supplementary information that could be construed as being covered by the
auditor’s opinion. Hence, the audit team should evaluate whether such supplementary
information is presented in a way that sufficiently and clearly differentiates it from the audited
financial statements. If not, then audit can suggest management to change the presentation of
unaudited supplementary information by:
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In the present case, there exists a material uncertainty that cast a significant doubt on the
company’s ability to continue as going concern and the same is not disclosed in the financial
statements of MOKSH Ltd.
As such, the financial statements of MOKSH Ltd. for the FY 2022 -23 are materially misstated
and the effect of the misstatement is so material and pervasive on the financial statements that
giving only a qualified opinion will be insufficient and therefore the statutory auditor of
MOKSH Ltd. should issue an adverse opinion.
The relevant extract of the Adverse Opinion Paragraph and Basis for Adverse Opinion
paragraph is as under:
Adverse Opinion
In our opinion, because of the omission of the information mentioned in the Basis for Adverse
Opinion section of our report, the accompanying financial statements do not present fairly, the
financial position of MOKSH Ltd. as at March 31, 2023, and of its financial performance and
its cash flows for the year then ended in accordance with the Accounting Standards issued by
the Institute of Chartered Accountants of India.
Basis for Adverse Opinion
MOKSH Ltd. has faced an extraordinary event (earthquake), which destroyed a lot of business
activity of the company. Due to such event, it may not be possible for the company to realize
its assets or pay off the liabilities during the regular course of its business. This situation
indicates that a material uncertainty exists that may cast significant doubt on the Company’s
ability to continue as a going concern. The financial statement and notes to the financial
statements of the company do not disclose this fact.
Question 2
While conducting audit of RAC Limited, CA R has discovered a misstatement in the financial
statements of a company due to non-write off of a huge trade receivable with an outstanding
amount of ₹ 2 crores. The party in question has fled from India and is now absconding. After
reviewing the audit evidence, it was concluded by the auditor that there is no possibility of
recovering the outstanding debt. Despite the matter being brought to the attention of the
management, they have refused to correct the misstatement. As a result, the financial
statements of the company show a profit before tax of ₹ 1 crore, which is incorrect due to the
management's refusal to correct the aforementioned misstatement. Materiality has been
determined for financial statements @ 5% of profit before tax. Comment as regards to type of
opinion to be given by CA R in above situation on the basis of provided information.
(Nov 2023 MTP 2)
Answer:
SA 705 states that the auditor shall modify the opinion in the auditor’s report when:
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(a) The auditor concludes that, based on the audit evidence obtained, the financial
statements as a whole are not free from material misstatement or
(b) The auditor is unable to obtain sufficient appropriate audit evidence to conclude that
the financial statements as a whole are free from material misstatement.
In the given situation, auditor has obtained evidence in relation to non-recoverability of
outstanding trade receivable.
SA 705 further states that the auditor shall express an adverse opinion when the auditor, having
obtained sufficient appropriate audit evidence, concludes that misstatements, individually or in
the aggregate, are both material and pervasive to the financial statements.
In this scenario, the uncorrected misstatement stands at 200% of the profit before tax, while
the materiality has been determined at 5% of the profit before tax. Hence, this misstatement
should be considered as material. Additionally, if such a substantial amount is written off, it
would significantly impact the financial position of the company. As a result, losses would
have to be reported instead of profits. Taking the above factors into consideration, this
misstatement should be classified as both material and pervasive. Therefore, adverse opinion
needs to be expressed in accordance with the requirements of SA 705.
Question 1 (SA 706)
How does the inclusion of Emphasis of Matter (EOM) paragraphs in the Auditor's Report differ
from the disclosure of Key Audit Matters (KAM)? (Nov 2023 RTP)
Answer:
Relationship between Emphasis of Matter Paragraphs and Key Audit Matters in
the Auditor’s Report
Key audit matters— Emphasis of Matter paragraph –
Those matters that, in the auditor’s A paragraph included in the auditor’s report
professional judgment, were of most that refers to a matter appropriately presented or
significance in the audit of the financial disclosed in the financial statements that, in the
statements of the current period. Key audit auditor’s judgment,is of such importance that
matters are selected from matters it is fundamental to users’ understanding of
communicated with those charged with the financial statements. [SA 706]
governance. [SA 701]
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Matters that are determined to be key audit A widespread use of Emphasis of Matter
matters in accordance with SA 701 may paragraphs may diminish the effectiveness
also be, in the auditor’s judgment, of the auditor’s communication about such
fundamental to users’ understanding of matters.
the financial statements. In such cases, Use of Emphasis of Matter paragraphs is not a
in communicating the matter as a keyaudit substitute for a description of individual key
matter in accordance with SA 701, the audit matters where SA 701 is applicable.
auditor may wish to highlight or draw
further attention to its relative importance.
Communicating key audit matters
There may be a matter that is not determined
provides additional information to
to be a key audit matter in accordance with SA
intended users of the financial
701 (i.e., because it did not require significant
statements to assist them in
auditor attention), but which, in the auditor’s
understanding those matters that, in the
judgment, is fundamental to users’
auditor’s professional judgment, were of
understanding of the financial statements(e.g., a
most significance in the audit and may
subsequent event). If the auditor considers it
also assist them in understanding the
necessary to draw users’ attention to such a
entity and areas of significant management
matter, the matter is included in an Emphasis
judgment in the audited financial
of Matter paragraph in the auditor’s report in
statements.
accordance with this SA.
The communication of key audit matters The auditor may do so by presenting the
in the auditor’s report may also provide matter more prominently than other matters
intended users a basis to further engage with in the Key Audit Matters section (e.g., as the
management and those charged with first matter) or by including additional
governance about certain matters relating information in the description of the key audit
to the entity, the audited financial matter to indicate the importance of the
statements, or the audit that was matter to users’ understanding of the financial
performed. statements.
(SA 720)
Question 1
Sujit & Co., Chartered Accountants, have been appointed as Statutory Auditors of Anand Mills
Ltd. for FY 2022-23. The audit team has completed the audit and is in the process of preparing
the audit report. The Management of the company has also prepared a draft annual report.
While reviewing the company's draft annual report, the auditor observed a section that stated a
decline in market prices for essential products compared to the previous year. Surprisi ngly,
the financial statements indicated that the company's profit margin had actually increased. The
audit Man ager discussed this issue with the firm's partner, who replied that the auditors are
not responsible for disclosures made by management in the annual report. Do you think that
the partner is correct in his approach to this issue? Discuss with reference to the relevant
Standards on Auditing the Auditor's duties with regard to reporting. (Nov 2023 MTP 1)
Answer:
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Auditor’s responsibilities as to Other Information included in Annual Report : SA 720,
"The Auditor's Responsibilities Relating to Other Information", delineates the responsibilities
of auditors in regard to other information, which can pertain to financial or non-financial
matters and is encompassed within an organisation's annual report. This encompasses
documentation of market trends pertaining to significant products and quantities or other items
that may be included in the other information.
The auditor’s discussion with management about a material inconsistency (or other information
that appears to be materially misstated) may include requesting management to provide support
for the basis of management’s statements in the other information. Based on management’s
further information or explanations, the auditor may be satisfied that the other information is
not materially misstated. For example, management explanations may indicate reasonable and
sufficient grounds for valid differences of judgment.
Auditor’s duties with regard to reporting: If the auditor concludes that a material
misstatement of the other information exists, the auditor shall request management to correct
the other information. If management:
(i) Agrees to make the correction, the auditor shall determine that the correction has been
made; or
(ii) Refuses to make the correction, the auditor shall communicate the matter with those
charged with governance and request that the correction be made.
In the given situation, Sujit & Co., Chartered Accountants, have been appointed as Statutory
Auditors of Anand Mills Ltd. The auditor, while reviewing the company’s draft annual report,
has observed a section mentioning about a decline in market prices for essential products
compared to previous year and financial statements indicated that company’s profit margin has
increased. Considering the requirements of SA 720 as stated above, it can be concluded that
contention of firm’s partner, that auditors are not responsible for disclosures made by
management, is not correct. Accordingly, partner is not correct in his approach to this issue.
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Chapter 2- CARO 2020
Question 1
CA. F has been appointed as the Statutory Auditor of XYZ Limited for the financial year 2022-
23. XYZ Limited has one subsidiary, namely AT Private Limited, whose statutory auditor is
CA. B for the same financial year i.e., 2022-23.
CA. B issued a qualification in CARO 2020 for AT Private Limited, stating that short -term
funds raised were utilised for long-term purposes. When consolidating the financial statements,
CA. F decided to include the aforementioned qualification in the audit report of the
Consolidated Financial Statements for the financial year 2022 -23. The management of XYZ
Limited argued that CA. F is not obligated to take into account and report the qualification
given by CA. B in the audit report of the subsidiary company in the consolidated financial
statements for the financial year 2022 -23.
Discuss the reporting requirement as per CARO, 2020. (Nov 2023 RTP)
Answer:
XYZ Limited is the parent company, and it has a subsidiary named AT Private Limited. CA F
is the appointed statutory auditor for XYZ Limited for the financial year 2022 -23. Another
auditor, CA B, has conducted the statutory audit for AT Private Limited and issued a CARO
2020 report, which includes a qualification regarding the short-term funds raised and utilised
for long-term purposes.
Provision of Paragraph 2 of CARO 2020: Paragraph 2 of CARO 2020 specifies that the
CARO provisions do not apply to the auditor's report on consolidated financial statements
except for clause (xxi) of Paragraph 3.
Clause (xxi) of Paragraph 3 of CARO 2020: Clause (xxi) of Paragraph 3 of CARO 2020
mandates the auditor to comment on whether there are any qualifications or adverse remarks
in the CARO reports of companies included in the consolidated financial statements. If such
qualifications or adverse remarks exist, the auditor is required to provide details of the
companies and the paragraph numbers of the CARO report containing those qualifications or
adverse remarks.
CA F's Responsibility: Considering the provisions stated above, CA F, as the auditor of XYZ
Limited's consolidated financial statements, is required to follow these steps:
a. Report under Clause (xxi) of Paragraph 3 of CARO 2020: CA F must include a
comment in the consolidated financial statement's audit report regarding whether there are any
qualifications or adverse remarks in the CARO reports of the companies included in the
consolidated financial statements.
b. Incorporate Qualification by CA B: CA F should incorporate the qualification made
by CA B (regarding short-term funds raised and utilized for long-term purposes in AT Private
Limited) into the auditor's report for XYZ Limited's consolidated financial statements.
c. Mention Paragraph Number: CA F must also provide the paragraph number of CA
B's CARO report where the qualification is stated.
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Management's Contention: The management of XYZ Limited's contention that CA F is not
required to consider and report CA B's qualification in the subsidiary's CARO report for the
consolidated financial statements is not valid. As per the provisions, CA F is indeed required
to report such qualifications as specified in Clause (xxi) of Paragraph 3 of CARO 2020.
In conclusion, based on the information provided and the provisions of CARO 2020, CA F is
obligated to incorporate the qualification from CA B's CARO report for AT Private Limited
into the auditor's report for XYZ Limited's consolidated financial statements for the financial
year 2022-23, as well as provide the necessary details as per the requirements of Clause (xxi)
of Paragraph 3 of CARO 2020.
Question 2
ABC & Associates are conducting audit of consolidated financial statements of “Crazy Paints
Limited” for year 2022-23. The consolidated financial statements consist of financial
statements of parent company and its five subsidiaries (audited by component auditors). While
drafting audit report in respect of consolidated financial statements under Companies Act,
2013, how firm should proceed to deal with issue of reporting under CARO, 2020?
(Nov 2023 MTP 2)
Answer:
CARO, 2020 specifically provides that it shall not apply to the auditor’s report on consolidated
financial statements except clause (xxi) of paragraph 3. This means that the auditor will need
to give a CARO report on the consolidated financial statements with respect to clause 3(xxi)
of the Order only. Thus, the auditor is not required to report on rest of the clauses of paragraph
3.
Clause 3(xxi) of CARO 2020 requires the auditor to state whether there have been any
qualifications or adverse remarks by the respective auditors in the Companies (Auditor’s
Report) Order (CARO) reports of the companies included in the consolidated financial
statements. If yes, indicate the details of the companies and the paragraph numbers of the
CARO report containing the qualifications or adverse remarks.
Therefore, it requires the auditor to provide details of the companies and the paragraph numbers
of the respective CARO report containing the qualifications or adverse remarks only. Reporting
under this is only required for those entities included in the consolidated financial statements
to whom CARO 2020 is applicable.
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Chapter 4- Professional Ethics
Question 1 Council Guidelines 2008
Comment on the following scenario with reference to the Chartered Accountants (Amendment)
Act, 2006 and Schedules thereto.
Statutory Audit of Arihant Limited for the year 2021-22 was done by CA Acharya. Arihant
Limited was in existence since 2010. The relevant extract from books of account of Arihant
Limited are as below:
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A member in practice shall be held guilty of professional misconduct as per clause 9 of Part I
of the First Schedule where he accepts an appointment as auditor of a company without first
ascertaining from it whether the requirements of Section 225 of the Companies Act, 1956 (1
of 1956), in respect of such appointment have been duly complied with (corresponding to
section 139 and 140 of Companies Act, 2013).
Clause (9) of Part I of the First Schedule to Chartered Accountants Act, 1949 provides
that a member in practice shall be deemed to be guilty of professional misconduct if he accepts
an appointment as auditor of a Company without first ascertaining from it whether the
requirements of Sections 139 and 140 of the Companies Act, 2013, in respect of such
appointment have been duly complied with. Under this clause, it is obligatory for the incoming
auditor to ascertain from the Company that the appropriate procedure in the matter of his
appointment has been duly complied with so that no shareholder or retiring auditor may, at a
later date, challenge the validity of such appointment.
As per section 139(8) of the Companies Act, 2013, any casual vacancy in the office of an
auditor shall in the case of a company other than a company whose accounts are subject to
audit by an auditor appointed by the Comptroller and Auditor-General of India, be filled by the
Board of Directors within thirty days, but if such casual vacancy is as a result of the resignation
of an auditor, such appointment shall also be approved by the company at a general meeting
convened within three months of the recommendation of the Board and he shall hold the office
till the conclusion of the next annual general meeting.
Also, before such appointment is made, the written consent of the auditor to such appointment
and a certificate from him or it that the appointment, if made, shall be in accordance with the
conditions as may be prescribed shall be obtained from the auditor. Provided also that the
certificate shall also indicate whether the auditor satisfies the criteria provided in section 141.
Also, that the company shall inform the auditor concerned of his or his appointment and also
file a notice of such appointment with the Registrar within fifteen days of the meeting in which
the auditor is appointed.
Also, a member in practice shall be held guilty of professional misconduct as per clause 8 of
Part I of the First Schedule where he accepts a position as auditor previously held by another
Chartered Accountant without first communicating with him in writing.
In the current case, Mr. Sunil was appointed statutory Auditor of M. Autotech Limited after
Mr. Ram resigned from the position of auditor on 31-07-2022 for the financial year 2022-23.
Mr. Sunil received the appointment letter duly signed by the Board of Directors. Mr. Sunil
received the letter of appointment on 31-07-2022, which he accepted on 01-08-2022. On 15-
08-2022, Mr. Sunil fixed a meeting with Mr. Ram to understand the reasons for his resignation
and any concerns he should be aware of about the company. Prior to this, no communication
happened between Mr. Sunil and Mr. Ram. The Board of M. Autotech Limited filed ADT-1
with the registrar on 31-08-2022.
Hence, Mr. Sunil did not verify whether the requirement of section 139 of the Companies Act,
2013 has been complied with or not, as in the current case, there was no approval by the
company at a general meeting convened within three months of the recommendation of the
Board. Under Section 139(8), approval by a company at general meeting as discussed above is
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mandatory requirement. Therefore, he has not ascertained from company whether requirements
of section 139 and 140 of Companies Act, 2013 have been complied with. Moreover, Mr. Sunil
did not communicate with a retiring auditor in such a manner as to retain in their hands positive
evidence of the delivery of the communication to the outgoing/previous auditor.
Therefore, Mr. Sunil is guilty of professional misconduct both under clause 8 and 9 of
First Schedule to Chartered Accountants Act, 1949.
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Keeping in view the facts, clause 6 and guideline issued by the council, it can be concluded
that M/s. SR & Associates is guilty of Professional misconduct.
Question 6
Mr. Raj, a practicing Chartered Accountant was ordered to surrender his certificate of practice
and he was suspended for two years for accepting the appointment as an auditor of a company
without ascertaining the requirements of section 139 and 140 read with section 141 of
Companies Act, 2013. During the period of suspension, Mr. Raj, designating himself as Data
Privacy consultant, did the work of filing Data Privacy related returns and made appearance as
a consultant before various related authorities in other capacity other than Chartered
Accountant in Practice. He contended that there is nothing wrong in it as he, like any other
consultant, could take such work and his engagement as such in no way violate the order of
suspension inflicted on him.
Kindly guide Mr. Raj whether can he appear before various Data Privacy related authorities
when he is under period of suspension in light of section 6 of the Chartered Accountants Act,
1949.
(Nov 2023 MTP 2)
Answer:
Section 6 of the Chartered Accountants Act, 1949 provides that: -
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i. No member of the Institute shall be entitled to practise whether in India or elsewhere
unless he has obtained from the Council a certificate of practice:
It may be noted that this provision is not applicable to any person who, immediately before the
commencement of this Act, has been in practice as a registered accountant or a holder of a
restricted certificate until one month has elapsed from the date of the first meeting of the
Council.
ii. Every such member shall pay such annual fee for his certificate as may be determined,
by notification, by the Council.
iii. The certificate of practice obtained under sub-section (1) may be cancelled by the
Council under such circumstances as may be prescribed.
Once the person concerned becomes a member of the Institute, he is bound by the provisions
of the Chartered Accountants Act and its Regulations. If and when he appears before the
Income -tax Tribunal as an Income-tax representative after having become a member of the
Institute, he could so appear only in his capacity as a Chartered Accountant and a member of
the Institute. Having, as it were, brought himself within the jurisdiction of the Chartered
Accountants Act and its Regulations, he could not set them at naught by contending that even
though he continues to be a member of the Institute and has been punished by suspension from
practice as a member, he would be entitled, in substance, to practice in some other capacity.
In the current case, Mr. Raj, designating himself as Data Privacy consultant, did the work of
filing Data Privacy related returns and made appearance as a consultant before various related
authorities in other capacity other than Chartered Accountant in Practice. As a result, h e is not
appearing in the capacity of Chartered Accountant in Practice and hence he is not violating the
suspension order.
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risks associated with an account balance, business process, transaction and activity level, which
form a sub-set of the overall enterprise risks.
This Enterprise Risk Management – Integrated Framework expands on internal control
providing a more robust and extensive focus on the broader subject of enterprise risk
management. While it is not intended to and does not replace the internal control framework,
but rather incorporates the internal control framework within it, companies may decide to look
to this enterprise risk management framework both to satisfy their internal control needs and
to move toward a fuller risk management process.
One of the most critical components of Enterprise Risk Management is the risk assessment
process. The risk assessment process involves considerations for: -
• Risk identification
• Assessment criteria including qualitative and quantitative factors
• Definition of key performance and risk indicators;
• Risk appetite
• Risk scores, scales and maps
• Assess risks
• Use of data & metrics
• Prioritise risk
• Benchmarking
Two most widely used ERM frameworks are: -
➢ COSO Enterprise Risk Management – Integrated Framework developed by the Committee
of Sponsoring Organisations (COSO) to address the changes in business environment.
➢ ISO 31000 Risk Management standard published by the International Organization for
Standardization. It is a risk Management standard published by the International
Organization for Standardization and provides guidelines on managing risk faced by
organizations. The application of these guidelines can be customized to any organization
and its context.
Question 2
CA. Sundaram is an engagement partner conducting a statutory audit of a nationalised bank. The bank operates on the
CBS platform, and the identification of NPAs is system based in accordance with RBI guidelines on asset classification.
He wants to be assured of satisfactory operation of internal control in this respect. He wants to be sure that there exists
an internal control system in the bank which not only prevents and reduces the risk of loan assets becoming non-
performing at the initial stages but also sends out timely signals to the bank subsequently. He is putting considerable
importance on effective credit appraisals due to their role in preventing NPA slippages.
While carrying out a walk-through of internal control over advances of banks especially in areas of “credit appraisals” and
“credit monitoring”, identify any four specific controls which you may be looking for.
(Nov 2023 RTP)
Answer:
The following controls may be considered by auditor in areas of credit appraisals and credit monitoring for
ensuring that internal control over advances is effective and the system is capable of not only preventing and
reducing the risk of NPAs at the sanction stage itself but also sending out timely signals to the bank subsequently.
(i) Use of third-party data sources in the bank for comprehensive due diligence at the sanction stage itself
to mitigate risk on account of misrepresentation and fraud.
(ii) Classification of accounts as special mentioned accounts (SMA) for early recognition of signs of
incipient stress resulting in default in timely servicing of debt obligations. It can enable banks to initiate
timely remedial actions to prevent potential slippages into NPAs.
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(iii) Institution of comprehensive, automated Early Warning Systems (EWS) in banks with EWS triggers
to detect stress and reduce slippage into NPAs
(iv) Reporting of repayment behaviour of borrowers in their loan accounts to credit information companies
and inclusion of this information in the credit appraisal and decision-making process for further
sanctioning of loans to borrowers.
Question 3
Advances generally constitute the major part of the assets of the bank. There are substantial
number of borrowers to whom a variety of advances are granted. The audit of advances
requires major attention from the auditors. As an expert in bank audit, you are required to
briefly discuss the area of focus and suggested audit procedures regarding the evaluation of
internal controls over advances, substantive audit procedures and recoverability of advances.
(Nov 2023 MTP 1)
Answer:
Audit Procedures -In carrying out audit of advances, the auditor is primarily concerned with
obtaining evidence about the following:
Area of Focus Suggested Audit Procedure
Evaluation of Internal • Examine loan documentation.
Controls over Advances
• Examine the validity of the recorded amounts.
• Examine the existence, enforceability and valuation of the
security.
• Ensure compliance with the terms of sanction and end use of
funds.
• Ensure compliance with Loan Policy of Bank as well as RBI
norms including appropriate classification and provisioning
• Review the operation of the accounts.
Substantive Audit • Check that the advances represent amount due to the bank.
Procedures
• Verify that the advances are disclosed, classified anddescribed
in accordance with recognised accounting policies and practices
and relevant statutory and regulatory requirements.
• Check that appropriate provisions towards advances have been
made as per the RBI norms, Accounting Standards and generally
accepted accounting practices.
• Examine all large advances while other advances may be
examined on a sample basis.
• Verify completeness and accuracy of interest being charged.
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• Ensure that there are no unrecorded advances.
• Check that the stated basis of valuation of advances is appropriate
and properly applied, and that the recoverability of advances is
recognised in their valuation.
• Check whether the amounts included in the balance sheet are
outstanding as on the date of balance sheet.
• Verify completeness and accuracy of interest being charged.
Question 4
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As a result of the above, the staff of the advances department in the branch is always on its
toes. The previous regular inspection of the branch (not pertaining to CA X’s tenure) had
pointed out huge revenue leakage in advances of the branch, raising alarm bells in the Zonal
Office and Inspection Department. Keeping in view the above situation, CA X is taking steps
to ensure that there is no revenue leakage in advances of the branch and recoveries are made
on the spot in case such leakages are detected. Discuss any five areas in this regard where
concurrent auditor’s audit procedures should be focused. (Nov 2023 MTP 2)
Answer:
The major areas to plug revenue leakage where concurrent auditor should focus audit
procedures include: -
(i) Verifying rates of interest as per terms of sanction in sanction letter vis-à-vis those fed
in CBS as well as the calculation of interest through product rate sheets generated by
CBS t o satisfy that interest has been charged on all the performing accounts and interest
rates charged are in accordance with the bank’s internal regulations, directives of the
RBI and agreements with the respective borrowers.
(ii) Verification of renewal charges in respect of existing customers enjoying cash credit
and export credit facilities. Similarly, for fresh borrowers, proposal processing charges,
including upfront fees for term loan, needs to be verified in accordance with Bank’s
circulars to ensure that all charges are debited at time of release of facilities to new
customers. These charges also need to be levied proportionately in respect of customers
whose credit facilities have been enhanced.
(iii) Verification of penal charges for non-submission of stock statements on due dates in
case borrowers availing cash credit and export credit facilities consisting of pre-
shipment credit facilities.
(iv) Verification of commission /charges in case of letter of credit has been issued to
importers in accordance with the Bank’s circulars.
(v) As the branch has also granted export credit facilities in the nature of post -shipment
credit facilities, verification of commission/charges on export bills purchased is
required.
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FY20-21 ₹ 6 Crore
FY21-22 ₹ 4 Crore
FY22-23 ₹ 1.5 Crore
Super Non-Bank Limited appointed Mr Shyam as their statutory auditor for the FY 22-23. Mr
Shyam identified that the Net Owned Funds of the company have been less than ₹ 2 Crore
since June 2022. Kindly guide Mr Shyam with respect to his reporting requirements as per
relevant NBFC provisions.
(Nov 2023 MTP 1)
Answer:
In exercise of the powers conferred under clause (b) of sub-section (1) of section 45–IA of the
RBI Act and all the powers enabling it in that behalf, the Bank hereby specifies two hundred
lakh rupees as the Net Owned Fund (NOF) required for a non-banking financial company to
commence or carry on the business of non-banking financial institution, except wherever
otherwise a specific requirement as to NOF is prescribed by the Bank.
It will be incumbent upon such NBFCs, the NOF of which currently falls below ₹200 lakh, to
submit a statutory auditor's certificate certifying compliance with the prescribed levels by the
end of the period as given above.
NBFCs failing to achieve the prescribed level within the stipulated period shall not be eligible
to hold the CoR as NBFCs. Every non-banking financial company shall submit a certificate
from its Statutory Auditor that it is engaged in the business of a non-banking financial
institution requiring it to hold a Certificate of Registration under Section 45-IA of the RBI Act
and is eligible to hold it. A certificate from the Statutory Auditor in this regard with reference
to the position of the company as at end of the financial year ended March 31 may be submitted
to the Regional Office of the Department of Non-Banking Supervision under whose
jurisdiction the non-banking financial company is registered, within one month from the date
of finalization of the balance sheet and in any case not later than December 30th of that year.
The format of the Statutory Auditor’s Certificate (SAC) to be submitted by NBFCs has been
issued vide DNBS. PPD.02/66.15.001/2016 -17 Master Direction- Non-Banking Financial
Company Returns (Reserve Bank) Directions, 2016.
Hence, in the current case, it is the responsibility of the Statutory Auditor, i.e., Mr. Shyam, to
report where NOF has fallen below ₹ 200 Lakhs.
Question 2
Suhana, a CA final student, is part of engagement team conducting audit of CMM Finance
Limited, a listed NBFC. While going through THE audit programme, she notices that it
contains instructions for verification of following matters among other things in relation to
disclosure requirements of Schedule III of Companies Act, 2013:
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(i) Verification regarding disclosure of any of item of income or expenditure which
exceeds 1% of revenue from operations or ₹10 lakhs whichever is higher.
(ii) Verification of disclosure regarding Return on Capital Employed Ratio, return on
Equity Ratio and net profit ratio.
Discuss whether above instructions for similar matters need revision by engagement partner in
this situation. If so, elaborate on revision required along with reasons. (Nov 2023 MTP 2)
Answer:
The above instructions are not proper and these do not pertain to Division III of Schedule III
applicable to NBFCs. Rather, such requirements are applicable for companies for which
Division II of Schedule III is applicable. Hence, these should be revised in accordance with
similar requirements applicable to listed NBFCs for whom Division III of Schedule III is
applicable.
The similar disclosure requirements for a listed NBFC under Division III of Schedule III are
as follows: -
(i) Any item of other income or other expenditure which exceeds 1% of total income
(ii) Disclosure of the following ratios: -
• Capital to risks-weighted assets ratio (CRAR)
• Tier I CRAR
• Tier II CRAR
• Liquidity coverage ratio
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NEMI Ltd. Unlisted Private 60 190 50 -
You are required to evaluate the requirements of the Companies Act, 2013 regarding the
appointment of internal Auditors for the Group Companies. Discuss. (Nov 2023 MTP 1)
Answer:
Applicability of Provisions of Internal Audit: As per section 138 of the Companies Act,
2013, following class of companies (prescribed in Rule 13 of Companies (Accounts) Rules,
2014) shall be required to appoint an internal auditor or a firm of internal auditors, namely:-
(A) every listed company;
(B) every unlisted public company having-
(1) paid up share capital of fifty crore rupees or more during the preceding financial year;
or
(2) turnover of two hundred crore rupees or more during the preceding financial year; or
(3) outstanding loans or borrowings from banks or public financial institutions exceeding
one hundred crore rupees or more at any point of time during the preceding financial
year; or
(4) outstanding deposits of twenty five crore rupees or more at any point of time during the
preceding financial year; and
(C) every private company having-
(1) turnover of two hundred crore rupees or more during the preceding financial year; or
(2) outstanding loans or borrowings from banks or public financial institutions exceeding
one hundred crore rupees or more at any point of time during the preceding financial
year.
In the given case, AADI Ltd. is a listed company. As per section 138 of the Companies Act,
2013, every listed company is required to appoint an internal auditor or a firm of internal
auditors. Thus, in view of the above, AADI Ltd. is required to appoint an internal auditor.
Further, AJIT Ltd. is unlisted public company. The company is having ₹ 60 crore as equity
share capital which is exceeding the prescribed limit of rupees fifty crore as per section 138.
Thus, AJIT Ltd. is required to appoint an internal auditor as per section 138 of the Companies
Act, 2013.
NEMI Ltd. is unlisted private company and having ₹ 60 crore as equity share capital, ₹ 190
crore as turnover and ₹ 50 crore loan from Bank and PFI. In view of provisions of section 138
of the Companies Act, 2013 discussed above, all the limits are below the prescribed limit for a
private company. Therefore, NEMI Ltd. is not required to appoint an internal auditor.
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It can be concluded that AADI Ltd. and AJIT Ltd. is required to appoint the internal auditor as
per the provisions of the Companies Act, 2013 whereas NEMI Ltd. is not required to do the
same.
Question 2
Consider the following statement:
“The internal auditor of a company shall be free from any undue influences which force him
to deviate from the truth. He shall be independent.”
Is above statement proper? If so, how independence of internal auditor can be established?
(Nov 2023 MTP 2)
Answer:
The Internal Auditor shall be free from any undue influences which force him to deviate from
the truth. This independence shall be not only in mind but also in appearance. Also, the internal
auditor shall resist any undue pressure or interference in establishing the scope of the
assignments or the manner in which these are conducted and reported, in case these deviate
from set objectives. The independence of the internal audit function and the Internal Auditor
within the organization is a vital aspect of maintaining effective corporate governance. It is
important to ensure that the internal audit function is free from any undue influence or pressure
that may affect its ability to provide impartial and objective assessments of the organization's
operations, risks, and controls.
Therefore, the given statement is proper.
To establish the independence of the Internal auditor, several factors need to be considered.
Firstly, the overall organizational structure of key personnel plays a crucial role. The Internal
auditor should be positioned in a way that allows them to operate independently and
objectively. This includes having direct access to the Audit Committee, Board of Directors,
and other senior executives. Secondly, the reporting line of the Chief Internal Auditor is an
important consideration. The Chief Internal Auditor should report to the highest level of
authority within the organization, such as the CEO or the Board of Directors. This ensures that
the Internal auditor has the necessary authority and support to carry out their responsibilities
effectively. Finally, the powers and authority derived from superiors further establish the
independence of the Internal auditor. The Internal auditor should have the necessary resources,
budget, and support to conduct their work without any undue influence or pressure from senior
executives or other stakeholders.
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CA. Kushal has been appointed as an Investigator by M/s. XYZ and Associates. While
undertaking this assignment of investigation, the subordinate staff of CA. Kushal inqui red
about the following issues:
(i) Whether an investigator is required to undertake the cent per cent verification
approach or whether he can adopt selective verification?
(ii) Whether an investigator necessarily requires assistance of expert?
(iii) Whether an investigator can retain working papers or not?
Guide CA. Kushal in solving the queries raised by his sub-ordinate staff. (Nov 2023 RTP)
Answer:
Investigations broadly range between two extremes; on the one hand there are those in respect
of which complete accounts, documents, records and other information are available, and on
the other, those in respect of which little information, besides published accounts and statistical
data, is available. Then again, investigation may cover the whole of accounting or may relate
to only a part or parts of accounting as may be specified. Some more issues often arise in
investigation. They are stated below:
(a) Whether an investigator is required to undertake a cent per cent verification
approach or whether he can adopt selective verification - The answer to this question
depends on the exact circumstances of the case under investigation. If the investigator has to
establish the amount of cash defalcated by the cashier, he has probably no option but to
carefully examine all the cash vouchers and related records. On the other hand, if he is to arrive
at the profitability of a concern, he may verify constituent transactions on a selective basis
taking extreme care to see that no material transaction that affects profit has remained
concealed from his eyes. In investigation, it is always safer to go by statistically recognised
sampling methods than to depend on the so-called “test checks” where circumstances permit
selective verification.
(b) Whether an investigator necessarily requires assistance of expert - Often an
investigator may feel the necessity of obtaining views and opinions of experts in various fields
to properly conduct the investigation. It would be therefore, proper for the investigator to get
the written general consent of his client, to refer special matters for views of different experts
at the beginning of investigation and he should settle the question of costs for obtaining the
views and other related implications.
(c) Whether to retain working papers or not - Another important precaution is that the
investigating accountant should retain in his files full notes of the work carried out, copies of
schedules and all working papers, annexures, facts, figures, record of conversations and the
like. Also, the working papers should link up the figures as shown by the books of business
with the final figures produced by the investigating accountant. Wherever required the
investigator should take representation letter from the appointing authority. In the absence
thereof, he would not be able to explain the figures when he is called upon to give evidence in
a court of law to support his figures; for quite often the conclusions of the accountant are
challenged by parties whose interest is adversely affected by his findings, for example, when
the value of shares of a company taken over by the Government has been determined by him.
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This will also be of immense help to the investigator in correlating facts and events and later
in drafting the report.
Repetitive questions
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