CMA Final · Cost and Management Audit
Companies (Cost Records and Audit) Rules, 2014: formula sheet
Key formulas
- Cost records power
- Section 148(1): order for a class of companies + prescribed goods or services → cost items included in books of account
- The Central Government must consult the regulator first if the class is regulated under a special Act.
- Cost audit power
- Section 148(2): covered under (1) + prescribed net worth or turnover + Government's opinion that audit is necessary → audit of cost records
- Cost audit is narrower than cost records. Not every company keeping cost records is audited.
- Appointment
- Section 148(3): cost accountant appointed by the Board; remuneration determined by members in the prescribed manner
- A section 139 auditor of the company cannot be appointed as cost auditor.
- Standards
- Section 148(3) second proviso: cost auditor must comply with cost auditing standards issued by the Institute of Cost Accountants of India with Central Government approval
- Link this to the Standards on Cost Auditing.
- Relationship with statutory audit
- Section 148(4): cost audit is in addition to the audit under section 143
- It never replaces the statutory audit.
- Report and filing
- Section 148(5)-(6): report goes to the Board of Directors; company furnishes the report to the Central Government within 30 days of receiving a copy, with full information and explanation on every reservation or qualification
- The 30 days run from the company's receipt of the report copy.
- Default
- Section 148(8): company and officers in default are punishable as per section 147(1); the cost auditor in default as per section 147(2) to (4)
- Penalty amounts are in section 147, not section 148.
- Cost records applicability (Rule 3)
- Company engaged in production of goods or services covered in Table A or Table B AND overall turnover of preceding year ≥ ₹35 crore
- Overall turnover means turnover from all products and services, including all units and branches.
- Cost audit: regulated sector (Rule 4)
- Table A company AND overall turnover ≥ ₹50 crore
- The company must also be covered by Rule 3, which it will be at this turnover.
- Cost audit: non-regulated sector (Rule 4)
- Table B company AND overall turnover ≥ ₹100 crore
- Below ₹100 crore, check the product-turnover limb of Rule 4.
- Cost audit: product turnover limb (Rule 4(3))
- Company covered under Rule 3 AND aggregate turnover of the individual product(s) or service(s) requiring cost audit ≥ ₹35 crore
- This is an alternative limb in Rule 4, set beside the overall turnover limit. The figure comes from the Rules and is not in Section 148 itself.
- Cost audit exemptions (Rule 4(4))
- Export revenue in foreign exchange > 75% of total revenue, OR company operates from a Special Economic Zone
- These exemptions remove the cost audit requirement only. Cost records under Rule 3 still apply.
- Statutory conditions on cost auditor (Section 148)
- Cost accountant appointed by Board; cannot be the Section 139 statutory auditor; audit is in addition to Section 143 audit
- Report goes to the Board. The company sends the report to the Central Government within thirty days of receiving it.
- Who keeps cost records
- Company covered by the applicability rule of the Rules → must keep cost records
- Maintenance is a separate step from applicability. A company must first fall within the Rules by industry and size.
- Form of records
- Cost records are kept in the CRA-1 format
- CRA-1 is for maintaining records. The cost audit report is a different form, CRA-3.
- Adequacy test
- Records must allow: cost per unit of production or operation, cost of sales, and margin, product-wise or activity-wise, for every financial year
- Kept on a regular basis, in line with cost accounting principles and Cost Accounting Standards.
- Place of keeping
- Registered office, or another place in India decided by the Board
- The Board decides. Write 'in India' in your answer.
- Retention period
- Not less than 8 years from the end of the financial year to which the records relate
- Count from the year end, not from the date of the entry.
- Cost records vs cost accounting records
- Cost records = cost accounting records + cost statements and other related records
- Cost accounting records cover material, labour and other inputs.
- Who appoints
- Cost auditor = cost accountant appointed by the Board (Section 148(3))
- Remuneration is determined by the members in the prescribed manner. The Board does not fix it alone.
- Bar on statutory auditor
- Section 139 auditor ≠ cost auditor
- The first proviso to Section 148(3): no person appointed under Section 139 as the company's auditor can be appointed to audit cost records.
- Standards
- Cost auditor must comply with cost auditing standards
- Standards are issued by the Institute of Cost Accountants of India with Central Government approval.
- Relation to financial audit
- Cost audit is in addition to Section 143 audit
- Section 148(4). It does not replace the statutory audit.
- Report goes to
- Cost auditor → Board of Directors
- Section 148(5) proviso. The company then sends a copy to the Central Government within 30 days of receiving it, with explanations on every reservation or qualification (Section 148(6)).
- Rule 6 steps (from the Rules, not the text above)
- Audit Committee recommendation → consent and certificate → Board appointment → member ratification of remuneration → CRA-2
- Check exact time limits in the current Rules before the exam.
- Who submits the report to whom
- Cost auditor → Board of Directors (Form CRA-3); Company → Central Government (Form CRA-4)
- Section 148(5) proviso: the report is submitted to the Board. Section 148(6): the company furnishes it to the Government.
- Time limit for CRA-3
- Cost auditor submits CRA-3 within 180 days from the end of the financial year
- Rule under the Companies (Cost Records and Audit) Rules, 2014. Count 180 days from the year end, not from the date of appointment.
- Time limit for CRA-4
- Company files CRA-4 within 30 days from the date of receipt of a copy of the cost audit report
- Section 148(6). The 30 days run from receipt by the company, not from the year end.
- Content of filing
- Report + full information and explanation on every reservation or qualification
- Section 148(6). Silence on a qualification is a defect in the filing.
- Standards to follow
- Cost auditor must comply with cost auditing standards
- Second proviso to section 148(3). Standards are issued by the Institute of Cost Accountants of India with Central Government approval.
- Relationship with statutory audit
- Cost audit is in addition to the section 143 audit
- Section 148(4). A person appointed as statutory auditor under section 139 cannot be appointed cost auditor (first proviso to 148(3)).
- Further information
- Central Government may call for further information; company furnishes it within the time specified
- Section 148(7).
- Rights and duties of cost auditor
- Section 148(5): auditor's qualifications, disqualifications, rights, duties and obligations apply to the cost auditor, so far as applicable
- This is why the cost auditor has the company auditor's right of access to books and records.
- Company's duty to assist
- Company must give all assistance and facilities to the cost auditor (Section 148(5))
- Cite this when a question says management refused records or access.
- Report recipient
- Cost audit report goes to the Board of Directors (proviso to Section 148(5))
- The cost accountant submits it to the Board, not directly to the Government.
- Filing with Government
- Within 30 days of receiving the report: furnish Central Government the report with full information and explanation on every reservation or qualification (Section 148(6))
- The duty is on the company. The 30 days run from receipt of the copy of the report.
- Further information
- Central Government may call for further information; company must furnish it within the time specified (Section 148(7))
- Triggered after the Government considers the report and the company's explanation.
- Penalty on default
- Company and officers in default: Section 147(1). Cost auditor in default: Section 147(2) to (4). Source: Section 148(8)
- Two different limbs. Do not mix them.
- Relationship with other audits
- Cost audit is in addition to Section 143 audit; the Section 139 auditor cannot be appointed as cost auditor (Section 148(3) and (4))
- A common one-line MCQ point.
Quick revision
- Section 148(1): the Central Government may direct that cost records be kept by specified classes of companies producing goods or providing services.
- Section 148(2): audit of cost records may be ordered for covered companies above prescribed net worth or turnover.
- Cost audit is appointed by the Board; remuneration is decided by the members in the prescribed manner.
- A person appointed as statutory auditor under Section 139 cannot be appointed to audit cost records of the same company.
- The cost auditor must comply with the cost auditing standards, which are issued by the Institute with Central Government approval.
- Cost audit is in addition to the audit under Section 143.
- The cost audit report is submitted to the Board of Directors.
- The company must furnish the report to the Central Government within thirty days of receiving a copy, with full information and explanation on every reservation or qualification.
- The Central Government may call for further information, which the company must furnish within the time it specifies.
- Qualifications, disqualifications, rights and duties of auditors under the Chapter apply to the cost auditor so far as applicable.
- The company must give the cost auditor all assistance and facilities.
- Default: the company and officers in default are punishable under Section 147(1); the cost auditor under Section 147(2) to (4).
Common mistakes
- Saying every company must get a cost audit under section 148. Fix: Write that the Central Government must direct a class of companies, and that cost audit needs both coverage under sub-section (1) and the prescribed net worth or turnover.
- Treating cost records and cost audit as the same thing. Fix: Keep two layers. Sub-section (1) is about records in books of account. Sub-section (2) is about auditing them.
- Treating cost records and cost audit as the same test. Fix: Answer in two lines: records applicable or not, audit applicable or not. Remember that records come first and audit is a subset.
- Applying ₹100 crore to a regulated-sector company or ₹50 crore to a non-regulated one. Fix: Tie the lower figure to the regulated sector: ₹50 crore for Table A and ₹100 crore for Table B. Anchor on the sector word in the question.
- Counting the eight years from the date of the transaction or from the date of the audit report. Fix: Count from the end of the financial year to which the records relate. For FY 2026-27, the end is 31 March 2027.
- Treating Form CRA-1 as the cost audit report form. Fix: Link CRA-1 with maintaining cost records. Link CRA-3 with the cost audit report.
- Saying members appoint the cost auditor. Fix: Remember Section 148(3): the Board appoints. The members' role is on remuneration only.
- Saying the Board fixes the cost auditor's remuneration. Fix: Write that remuneration is determined by the members in the prescribed manner, as the Act says.
- Saying the cost auditor files the report with the Central Government. Fix: Remember the proviso to section 148(5): the auditor reports to the Board. Section 148(6) puts the filing duty on the company.
- Counting the 30 days for CRA-4 from the financial year end. Fix: CRA-4 runs from the date the company receives a copy of the report. Underline the trigger date in the question.
Exam tips
- In theory answers, name the sub-section: (1) records, (2) audit, (3) appointment, (4) in addition to section 143, (5) report to Board, (6) filing within 30 days, (8) default.
- For applicability cases, show the two-gate test in writing, with the figures compared against the limits, then a one-line conclusion.
- In MCQs, watch for traps: statutory auditor as cost auditor, report sent directly to the Government, and cost audit replacing the section 143 audit.
- Do not quote penalty amounts under section 148. Say the penalty follows section 147 and give the sub-section split for company and cost auditor.
- Revise this topic with the Rules on cost records, appointment and the report, since questions often combine them in one case.
- In case-based MCQs the answer is often decided by one detail: the sector table, the preceding year, an SEZ unit or the export share. Underline these before computing.
- In written answers, give a separate conclusion for cost records and for cost audit. Examiners reward the split.
- Always compare the product turnover with ₹35 crore when overall turnover is below the audit limit.