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ICAI Specific aspects to regulate audit quality include integration of financial statement reporting with Internal Financial Controls, restrictions on auditors rendering conflicting services, audit rotation, audit limits and penalties on the audit profession have been included in the new Act. Similarly entity level discipline is sought to be enhanced by significant controls over related party transactions, acceptance of deposits, code of independent directors, mandatory internal audits for large enterprises, enhanced board responsibility etc. These controls enshrined in the Act, in addition to the efforts of ICAI will enable higher audit quality especially for public interest entities. Incremental benefits by creating NFRA need to be reexamined before notification of Section 132.

132.Constitution In section 132 a) after sub- 132. Constitution of of Natural of the principal section (1), the National Financial Financial Act,-- following sub- Reporting Authority.
                   Reporting                                     section      shall
                                          (i)   in     sub-                           (1)     The      Central
                   Authority.-- (1) section (4), in               be inserted,         Government         may,
                   The           Central clause (c), in          namely--              by notification,
                   Government may, sub-clause (A),               "(1-A)        The    constitute a National
                   by       notification, in item (II), for      National             Financial     Reporting
                   constitute           a the words              Financial            Authority to provide
                   National Financial                            Reporting            for matters relating to
                   Reporting              "ten         lakh
                                                                 Authority    shall   accounting
                   Authority           to rupees",       the
                                                                 perform        its   and auditing
                   provide for matters words "five lakh          functions through    standards under     this
                   relating            to rupees" shall be       such divisions as    Act.
                   accounting        and substituted;            may            be (1A)
                   auditing standards (ii) in sub-                                           The     National







                    under this Act.       section (5), for        prescribed.";        Financial    Reporting
                                         the       words,                             Authority         shall
                                         brackets     and                             perform its functions
                   (2)                   figure       "the       (b) after sub- through                 such
                   Notwithstanding       Appellate               section (3), the divisions as may be
                   anything contained Authority                  following      sub- prescribed.]
                   in any other law for                          sections       shall
                   the time being in constituted                                      (2) Notwithstanding
                                                                 be inserted,
                   force, the National under         sub-                             anything contained in
                                                                 namely--
                                         section (6) in                               any other law for the
                   Financial             such manner as          "(3-A)         Each time being in force,
                   Reporting             may            be       division of the the National Financial
                   Authority shall--      prescribed", the        National             Reporting Authority
                                                                 Financial
                   (a)            make words                                          shall--
                                                                 Reporting
                   recommendations       "the Appellate          Authority shall be (a)                make
                   to    the    Central Tribunal in such                              recommendations      to
                                                                 presided over by
                   Government on the manner and on                                    the            Central
                                                                 the Chairperson
                   formulation      and payment of such
                                                                 or a full-time Government on the
                   laying down of        fee as may be                                formulation and laying
                                                                 Member
                   accounting       and prescribed"              authorised by the down of accounting
                   auditing    policies shall                                         and auditing policies
                                                        be       Chairperson.
                   and standards for substituted;                                     and standards for
                                                                 (3-B) There shall adoption                by
                   adoption           by
                                                                 be an executive companies or class of
                   companies or class
                                                                 body      of     the companies or their
                   of companies or       (iii)       sub-
                                                                 National             auditors, as the case
                   their auditors, as sections (6), (7),         Financial            may be;
                   the case may be;      (8) and (9) shall
                                                                 Reporting
                                         be omitted.                                  (b)    monitor     and
                   (b) monitor and                               Authority
                                                                                      enforce             the
                   enforce           the                         consisting of the
                   compliance      with                          Chairperson and compliance
                                                                                      with accounting
                   accounting                                    full-time
                   standards        and                          Members of such standards and auditing
                                                                                  for standards in      such
                   auditing standards                            Authority
                                                                                      manner as may be
                   in such                                       efficient
                                                                 discharge of its prescribed;
                   manner as may be                              functions under (c) oversee the quality
                   prescribed;                                   sub-section      (2) of service of the
                   (c) oversee the                               [other than clause professions associated
                   quality of service                            (a)] and sub- with                 ensuring
                   of the professions                            section (4).";       compliance with such
                   associated    with                            (c) in sub-section standards, and suggest
                   ensuring                                      (4), in clause (c), measures required for
                                                                         sub-clause improvement
                   compliance with                                                                         in
                                                                 for
                   such standards, and                           (B), the following quality of service and
                   suggest measures                              sub-clause shall such other related







                    required       for                            be substituted,       matters as may        be
                   improvement     in                            namely--               prescribed; and
                   quality of service                            "(B) debarring the (d) perform such other
                   and such other                                member or the functions relating to
                   related matters as                            firm from--         clauses (a), (b) and
                   may be prescribed;                            I. being appointed (c) as     may      be
                   and                                           as an auditor or prescribed.
                   (d) perform such                              internal auditor or   (3)    The     National
                   other      functions                          undertaking any       Financial    Reporting
                   relating to clauses                           audit in respect of   Authority shall consist
                   (a), (b) and (c) as                           financial             of a chairperson, who
                   may be prescribed.                            statements       or   shall be a person of
                                                                 internal audit of     eminence and having
                                                                 the functions and     expertise             in
                   (3) The National                              activities of any     accountancy, auditing,
                   Financial                                     company or body       finance or law to be
                   Reporting                                     corporate; or         appointed     by     the
                   Authority       shall                                               Central Government
                                                                 II. performing any
                   consist     of     a                                                and                 such
                                                                 valuation        as
                   chairperson, who                                                    other members not
                                                                 provided     under
                   shall be a person                                                   exceeding        fifteen
                                                                 Section 247, for a
                   of eminence and                                                     consisting of part-time
                                                                 minimum period
                   having expertise in                           of six months or      and                 full-
                   accountancy,                                  such        higher    time members as may
                   auditing, finance or                                                be prescribed:
                                                                 period         not
                   law to be appointed                           exceeding       ten   [(3A) Each division of
                   by the Central                                years as may be       the National Financial
                   Government     and                            determined by the     Reporting Authority
                   such          other                           National              shall be presided over
                   members         not                           Financial             by the Chairperson or
                   exceeding fifteen                             Reporting             a full-time Member
                   consisting of part-                           Authority.".          authorised by the
                   time and full-time                                                  Chairperson.
                   members                                                             (3B) There shall be an
                   as      may        be                                               executive body of the
                   prescribed:                                                         National      Financial
                                                                                       Reporting Authority
                   Provided that the                                                   consisting    of    the
                   terms           and                                                 Chairperson and full-
                   conditions and the                                                  time Members of such
                   manner           of                                                 Authority for efficient
                   appointment of the                                                  discharge     of     its
                   chairperson and                                                     functions under sub-
                   members shall be                                                    section (2) [other than







                    such as may be                                clause (a)] and sub-
                   prescribed:                                   section (4).]
                   Provided      further                         Provided that the
                   that the chairperson                          terms and conditions
                   and members shall                             and the manner of
                   make a declaration                            appointment of the
                   to the Central                                chairperson
                                                                 and members shall be
                   Government in the
                                                                 such as     may   be
                   prescribed     form
                                                                 prescribed:
                   regarding        no
                   conflict of interest                          Provided further that
                   or      lack      of                          the         chairperson
                   independence      in                          and members shall
                   respect of                                    make a declaration to
                                                                 the             Central
                   his    or    their
                                                                 Government            in
                   appointment:
                                                                 the prescribed     form
                   Provided also that                            regarding no conflict
                   the chairperson and                           of interest or lack of
                   members, who are                              independence          in
                   in         full-time                          respect of his or their
                   employment with                               appointment:
                   National
                                                                 Provided also that the
                   Financial                                     chairperson
                   Reporting                                     and members, who are
                   Authority shall not                           in            full-time
                   be associated with                            employment         with
                   any audit firm                                National      Financial
                   (including related                            Reporting Authority
                   consultancy                                   shall not be associated
                   firms) during the                             with any audit firm
                   course of their                               (including      related
                   appointment   and                             consultancy      firms)
                   two years after                               during the course of
                   ceasing to hold                               their appointment and
                   such appointment.                             two years after ceasing
                                                                 to      hold       such
                                                                 appointment.
                   (4)                                           (4) Notwithstanding
                   Notwithstanding                               anything contained in
                   anything contained                            any other law for the
                   in any other law for                          time being in force,
                   the time being in                             the National Financial
                   force, the National                           Reporting Authority







                    Financial                                     shall--
                   Reporting                                     (a) have the power to
                   Authority shall--                              investigate, either suo
                   (a) have the power                            moto or on a reference
                   to      investigate,                          made to it by the
                   either suo motu or                            Central Government,
                   on a reference                                for such class of
                   made to it by the                             bodies corporate or
                   Central                                       persons,     in    such
                                                                 manner as may be
                   Government,     for
                                                                 prescribed into     the
                   such     class   of
                                                                 matters of professional
                   bodies corporate or
                                                                 or other misconduct
                   persons, in such
                                                                 committed by any
                   manner as may be
                                                                 member or firm of
                   prescribed into
                                                                 chartered accountants,
                   the matters of                                registered under the
                   professional   or                             Chartered Accountants
                   other misconduct                              Act, 1949:
                   committed by any
                                                                 Provided that no other
                   member or firm of
                                                                 institute or body shall
                   chartered
                                                                 initiate or continue any
                   accountants,                                  proceedings in such
                   registered under the                          matters of misconduct
                   Chartered                                     where the National
                   Accountants Act,                              Financial     Reporting
                   1949 ( 38 of 1949):                           Authority has initiated
                   Provided that no                              an investigation under
                   other institute or                            this section;
                   body shall initiate                           (b) have the same
                   or continue any                               powers as are vested
                   proceedings in such                           in a civil court under
                   matters                                       the Code of Civil
                   of        misconduct                          Procedure,       1908,
                   where the National                            while trying a suit, in
                   Financial                                     respect     of      the
                   Reporting                                     following      matters,
                   Authority        has                          namely:-
                   initiated         an                          (i) discovery and
                   investigation under                           production of books of
                   this section;                                 account and
                                                                 other documents,     at
                   (b) have the same                             such place and at such
                   powers    as   are                            time as may be
                   vested in a civil







                    court under the                               specified   by     the
                   Code    of    Civil                           National    Financial
                   Procedure, 1908 (                             Reporting Authority;
                   5 of 1908), while                             (ii) summoning and
                   trying a suit, in                             enforcing         the
                   respect   of  the                             attendance of persons
                   following matters,                            and examining them
                   namely:--                                      on oath;
                   (i) discovery and                             (iii) inspection of any
                   production      of                            books, registers and
                   books of account                              other documents of
                   and          other                            any person referred to
                   documents, at such                            in clause (b) at any
                   place and at                                  place;
                   such time as may                              (iv)          issuing
                   be specified by the                           commissions       for
                   National Financial                            examination        of
                   Reporting                                     witnesses
                   Authority;                                    or documents;
                   (ii) summoning and                            (c) where professional
                   enforcing      the                            or other misconduct is
                   attendance      of                            proved,    have    the
                   persons        and                            power to make order
                   examining them on                             for--
                   oath;                                         (A) imposing penalty
                   (iii) inspection of                           of--
                   any           books,                          (I) not less than one
                   registers and other                           lakh rupees, but which
                   documents of any                              may extend to five
                   person referred to                            times of the fees
                   in                                            received, in case of
                   clause (b) at any                             individuals; and not
                   place;                                        less than 1[five lakh
                                                                 rupees], but which
                   (iv)        issuing
                                                                 may extend to ten
                   commissions     for
                                                                 times of the fees
                   examination      of
                                                                 received, in case of
                   witnesses        or
                                                                 firms;
                   documents;
                                                                 [(B) debarring the
                   (c)          where
                                                                 member or the firm
                   professional    or
                                                                 from--
                   other misconduct is
                   proved, have the                              I. being appointed as
                   power to make                                 an auditor or internal







                    order for--                                    auditor or undertaking
                                                                 any audit in respect of
                   (A)       imposing
                                                                 financial statements or
                   penalty of--
                                                                 internal audit of the
                   (I) not less than one                         functions          and
                   lakh rupees, but                              activities           of
                   which may extend                              any company or body
                   to five times of the                          corporate; or
                   fees received,
                                                                 II. performing any
                   in      case     of                           valuation as provided
                   individuals; and                              under section 247, for
                   (II) not less than                            a minimum period of
                   ten lakh rupees, but                          six months or such
                   which may extend                              higher period not
                   to ten times of the                           exceeding ten years as
                   fees received,                                may be determined by
                                                                 the National Financial
                   in case of firms;                             Reporting Authority.]
                   (B) debarring the                             Explanation.-For the
                   member or the firm                            purposes of his sub-
                   from      engaging                            section, the expression
                   himself or itself                             "professional or other
                   from practice as                              misconduct"       shall
                   member of the                                 have      the     same
                   Institute         of                          meaning assigned to it
                   Chartered                                     under section 22 of the
                   Accountant        of                          Chartered Accountants
                   India referred to in                          Act, 1949.
                   clause (e) of sub-                            (5)     Any      person
                   section                                       aggrieved by any order
                   (1) of section 2 of                           of     the     National
                   the       Chartered                           Financial     Reporting
                   Accountants Act,                              Authority issued under
                   1949 (38 of 1949)                             clause (c) of sub-
                   for a minimum                                 section (4), may prefer
                   period of six                                 an               appeal
                                                                 before [the Appellate
                   months or for such                            Tribunal in        such
                   higher period not                             manner       and     on
                   exceeding ten years                           payment of such fee as
                   as may be decided                             may be prescribed].
                   by the National
                                                                 (6)[Omitted]
                   Financial
                   Reporting                                     (7)[Omitted]








                    Authority.                                    (8)[Omitted]
                   Explanation.--For                              (9)[Omitted]
                   the purposes of this                          (10) The National
                   sub-section,     the                          Financial     Reporting
                   expression                                    Authority shall meet at
                   "professional     or                          such times and places
                   other misconduct"                             and shall observe such
                   shall have the same                           rules of procedure in
                   meaning assigned                              regard       to     the
                   to it under section                           transaction of business
                   22 of the Chartered                           at its meetings in such
                   Accountants Act,                              manner as may be
                   1949 ( 38                                     prescribed.
                   of 1949).                                     (11)     The    Central
                                                                 Government         may
                                                                 appoint a secretary and
                   (5) Any person                                such other employees
                   aggrieved by any                              as it may consider
                   order     of    the                           necessary for the
                   National Financial                            efficient performance
                   Reporting                                     of functions by the
                   Authority    issued                           National      Financial
                   under                                         Reporting Authority
                   clause (c) of sub-                            under this Act and the
                   section (4), may                              terms and conditions
                   prefer an appeal                              of service of the
                   before         the                            secretary           and
                   Appellate                                     employees shall be
                   Authority                                     such as     may      be
                   constituted under                             prescribed.
                   sub-                                          (12) The head office
                   section (6) in such                           of     the     National
                   manner as may be                              Financial     Reporting
                   prescribed.                                   Authority shall be at
                                                                 New Delhi and the
                                                                 National      Financial
                   (6) The Central                               Reporting Authority
                   Government may,                               may, meet at such
                   by      notification,                         other places in India as
                   constitute,     with                          it deems fit.
                   effect from such                              (13) The National
                   date as may be                                Financial   Reporting
                   specified therein,                            Authority shall cause
                   an       Appellate                            to   be    maintained







                    Authority                                     such books            of
                   consisting of a                               account and       other
                   chairperson and not                           books in relation to its
                   more then two                                 accounts in such form
                   other                                         and in such manner as
                                                                 the              Central
                   members, to be
                                                                 Government may, in
                   appointed by the
                                                                 consultation with the
                   Central
                                                                 Comptroller         and
                   Government,      for
                                                                 Auditor-General       of
                   hearing      appeals
                                                                 India prescribe.
                   arising out of the
                   orders of the                                 (14) The accounts of
                                                                 the National Financial
                   National Financial
                                                                 Reporting Authority
                   Reporting
                                                                 shall be audited by the
                   Authority.
                                                                 Comptroller        and
                                                                 Auditor-General      of
                   (7)            The                            India at such intervals
                   qualifications for                            as may be specified by
                   appointment of the                            him and such accounts
                   chairperson    and                            as certified by the
                   members of the                                Comptroller        and
                   Appellate                                     Auditor-General      of
                   Authority,                                    India together with the
                                                                 audit report thereon
                   the manner of                                 shall be forwarded
                   selection, the terms                          annually to the Central
                   and conditions of                             Government by the
                   their service and                             National      Financial
                   the requirement of                            Reporting Authority.
                   the supporting
                                                                 (15) The National
                   staff and procedure                           Financial    Reporting
                   (including places of                          Authority         shall
                   hearing           the                         prepare in such form
                   appeals, form and                             and at such time for
                   manner in which                               each financial year as
                   the appeals shall                             may be prescribed its
                   be filed) to be                               annual report giving a
                   followed by the                               full account of its
                   Appellate                                     activities      during
                   Authority shall be                            the financial year and
                   such as may be                                forward a copy thereof
                   prescribed.                                   to      the    Central
                                                                 Government and the
                                                                 Central Government







                    (8) The fee for                               shall cause the annual
                   filing the appeal                             report and the audit
                   shall be such as                              report given by the
                   may be prescribed.                            Comptroller         and
                                                                 Auditor-General      of
                                                                 India to be laid before
                   (9) The officer                               each      House      of
                   authorised by the                             Parliament.
                   Appellate
                   Authority    shall
                   prepare in such
                   form and at such
                   time as
                   may be prescribed
                   its annual report
                   giving      a   full
                   account      of  its
                   activities      and
                   forward a copy
                   thereof to the
                   Central
                   Government     and
                   the         Central
                   Government shall
                   cause the annual
                   report to be laid
                   before each
                   House              of
                   Parliament.


                   (10) The National
                   Financial
                   Reporting
                   Authority     shall
                   meet at such times
                   and places and
                   shall
                   observe such rules
                   of procedure in
                   regard     to  the
                   transaction     of
                   business at its
                   meetings in such








                    manner as
                   may be prescribed.


                   (11) The Central
                   Government may
                   appoint a secretary
                   and such other
                   employees as it
                   may consider
                   necessary for the
                   efficient
                   performance     of
                   functions by the
                   National Financial
                   Reporting
                   Authority under
                   this Act and the
                   terms          and
                   conditions       of
                   service    of   the
                   secretary      and
                   employees shall be
                   such as may be
                   prescribed.


                   (12) The head
                   office    of    the
                   National Financial
                   Reporting
                   Authority shall be
                   at New Delhi and
                   the
                   National Financial
                   Reporting
                   Authority      may,
                   meet at such other
                   places in India as it
                   deems fit.


                   (13) The National
                   Financial







                    Reporting
                   Authority     shall
                   cause     to     be
                   maintained    such
                   books of account
                   and other books in
                   relation   to   its
                   accounts in such
                   form and in such
                   manner as the
                   Central
                   Government
                   may,             in
                   consultation with
                   the     Comptroller
                   and        Auditor-
                   General of India
                   prescribe.


                   (14) The accounts
                   of the National
                   Financial
                   Reporting
                   Authority shall be
                   audited by the
                   Comptroller     and
                   Auditor-General of
                   India     at   such
                   intervals as may be
                   specified by him
                   and such accounts
                   as certified by the
                   Comptroller     and
                   Auditor-General of
                   India together with
                   the audit report
                   thereon shall be
                   forwarded annually
                   to    the    Central
                   Government by the
                   National Financial
                   Reporting
                   Authority.









                    (15) The National
                   Financial
                   Reporting
                   Authority       shall
                   prepare in such
                   form and at such
                   time     for    each
                   financial year as
                   may be prescribed
                   its annual report
                   giving      a    full
                   account      of    its
                   activities during the
                   financial year and
                   forward a copy
                   thereof     to    the
                   Central
                   Government       and
                   the           Central
                   Government shall
                   cause the annual
                   report and the audit
                   report given by the
                   Comptroller      and
                   Auditor-General of
                   India to be laid
                   before each House
                   of Parliament


W.P.(C) 1065/2021 & other connected matters Page 58 of 476 Signature Not Verified Digitally Signed By:KAMLESH KUMAR Signing Date:07.02.2025 18:46:26

31. Pursuant to the provisions contained in clauses (2) and (3) of Rule 3, every existing body corporate other than a company governed by that Rule is obliged to furnish the particulars of its auditors in Form NFRA-I.

32. Apart from the various functions and obligations which have been placed upon the NFRA by virtue of Section 132(2), one of its principal statutory responsibilities is to undertake an investigation and inquiry in respect of professional or other misconduct. This power flows from sub-section (4) of Section 132 which empowers the NFRA to undertake disciplinary action against a member or firm of chartered accountants registered under the CA Act. By virtue of the Proviso appended to Section 132(4), no institute or body is entitled to initiate or continue proceedings in respect of misconduct once the NFRA has commenced an investigation in terms of that Section. Section 132(4) thus confers a power upon the NFRA to initiate an investigation either suo moto or on a reference made to it by the Union Government. The penalties which it could impose, in case where professional or other misconduct is proved, is set out in Section 132(4)(c). As is manifest from a reading of that provision, the NFRA stands empowered to impose not just monetary penalties but also debar a member or the firm from being appointed as an auditor, internal auditor or undertaking an audit in respect of financial statements of any company or body corporate for a minimum period of six months or such larger period not exceeding 10 years as may be determined by the NFRA.