CMA Final · Cost and Management Audit
Cost Auditor: formula sheet
Key formulas
- Who conducts the audit
- Cost audit under S.148(2) is conducted by a cost accountant appointed by the Board
- Section 148(3). The Board appoints; members determine the remuneration in the prescribed manner.
- Statutory auditor bar
- Auditor appointed under S.139 cannot be appointed as cost auditor of the same company
- First proviso to Section 148(3). Protects independence.
- Cost auditing standards
- Cost auditor must comply with cost auditing standards issued by the Institute of Cost Accountants of India with Central Government approval
- Second proviso and Explanation to Section 148(3).
- Relation to financial audit
- Cost audit is in addition to audit under Section 143
- Section 148(4).
- Report recipient
- Cost auditor submits the report to the Board of Directors
- Proviso to Section 148(5).
- Company's filing after report
- Furnish report to Central Government within 30 days of receiving a copy, with explanation on every reservation or qualification
- Section 148(6). This is the company's duty after the audit, not the appointment filing.
- Form CRA-2 timeline
- Earlier of: 30 days from the Board meeting appointing the cost auditor, or 180 days from the start of the financial year
- Stated in the Cost Records and Audit Rules. Calculate both dates and take the earlier.
- Audit Committee role
- Board appoints on the recommendation of the Audit Committee, where one exists
- From the Rules. Remuneration is then ratified by members.
- Who audits cost records
- Cost accountant appointed by the Board (section 148(3))
- Remuneration is determined by the members in the prescribed manner.
- Statutory auditor bar
- Person appointed under section 139 as auditor ⇒ cannot be appointed for cost audit
- First proviso to section 148(3). Cost auditor and statutory auditor must be different persons.
- Standards to follow
- Cost auditor must comply with the cost auditing standards
- Standards are issued by the Institute of Cost Accountants of India with Central Government approval (Explanation to section 148(3)).
- Borrowed auditor provisions
- Section 148(5): qualifications, disqualifications, rights, duties and obligations of auditors apply to cost auditor so far as applicable
- This is the route by which section 141(3) disqualifications reach the cost auditor.
- Relation to statutory audit
- Cost audit is in addition to audit under section 143
- Section 148(4).
- Disqualification arising after appointment
- Vacate office; deemed casual vacancy (section 141(4))
- Applies if a disqualification under section 141(3) is incurred after appointment.
- Report recipient
- Cost audit report is submitted to the Board of Directors
- Proviso to section 148(5).
- Source of power
- Section 148(1): cost records; Section 148(2): cost audit
- Central Government acts by order, for a class of companies, based on prescribed net worth or turnover.
- Cost records test (Rules)
- Company in a listed regulated or non-regulated industry AND overall turnover of preceding year ≥ ₹35 crore
- Covers all products and services of the company, including units and branches. Check the exemptions.
- Cost audit test: regulated sector (Rules)
- Overall turnover ≥ ₹50 crore OR aggregate turnover of an individual product or service > ₹25 crore
- Applies to companies already covered for cost records. Confirm limits against the current Rules text.
- Cost audit test: non-regulated sector (Rules)
- Overall turnover ≥ ₹100 crore OR aggregate turnover of an individual product or service > ₹35 crore
- Applies to companies already covered for cost records. Note ≥ for overall and > for individual product, as in the Rules.
- Cost auditor and statutory auditor
- Cost auditor = cost accountant appointed by the Board; the Section 139 auditor cannot be appointed
- Section 148(3). The report goes to the Board (Section 148(5) proviso).
- Report to Government
- Company furnishes cost audit report to the Central Government within 30 days of receiving a copy
- Section 148(6), with full information and explanation on every reservation or qualification.
- Rights and duties of a cost auditor
- Section 148(5): auditor's qualifications, disqualifications, rights, duties and obligations apply to a cost auditor, so far as applicable
- This is how a cost auditor gets rights such as access to records. Say 'so far as may be applicable' in your answer.
- Company's duty to the cost auditor
- Company must give all assistance and facilities to the cost auditor (Section 148(5))
- Use this to answer questions on obstruction or non-cooperation.
- Whom the cost auditor reports to
- Cost auditor → Board of Directors (proviso to Section 148(5))
- The report goes to the Board, not directly to the Central Government.
- Company's filing duty
- Within 30 days of receiving the cost audit report: furnish to Central Government with full information and explanation on every reservation or qualification (Section 148(6))
- The 30 days run from the company's receipt of the report. The duty is on the company.
- Further information
- Central Government may call for further information; company furnishes within time specified (Section 148(7))
- Applies after the Government has considered the report and the company's explanation.
- Relation to financial audit
- Cost audit is in addition to the section 143 audit (Section 148(4))
- The cost auditor must not be the company's section 139 auditor (first proviso to Section 148(3)).
- Standards
- Cost auditor must comply with the cost auditing standards (second proviso to Section 148(3))
- These standards are issued by the Institute of Cost Accountants of India with Central Government approval.
- Penalty for default
- Company and officers in default: as in section 147(1). Cost auditor in default: as in section 147(2) to (4) (Section 148(8))
- Do not quote amounts unless the question gives them.
- Appointment and remuneration
- Cost auditor appointed by the Board; remuneration determined by the members in the prescribed manner
- Section 148(3). Do not say the Board fixes the fee.
- Who cannot be cost auditor
- Person appointed under Section 139 as company auditor cannot be appointed for the cost audit
- First proviso to Section 148(3). The cost auditor must be a cost accountant.
- Standards to follow
- Cost auditor must comply with the cost auditing standards
- Second proviso to Section 148(3). Standards are issued by the Institute with Central Government approval.
- Report submission
- Cost audit report goes to the Board; company furnishes it to the Central Government within 30 days of receiving a copy
- Section 148(5) proviso and Section 148(6), with full information and explanation on every reservation or qualification.
- Penalty on default
- Company and officers in default: as per Section 147(1). Cost auditor in default: as per Section 147(2) to (4)
- Section 148(8).
- Lesser penalty
- Not more than one-half of the penalty, subject to a maximum of ₹2,00,000 for a company and ₹1,00,000 for an officer in default or other person
- Section 446B. Applies to One Person Company, small company, start-up company and Producer Company.
- Resignation statement (by analogy)
- Auditor who resigns files a statement in the prescribed form with the company and the Registrar within 30 days of resignation
- Section 140(2) for the Section 139 auditor. Apply to the cost auditor only so far as applicable under Section 148(5).
Quick revision
- Section 148 lets the Central Government direct that cost records be kept by specified classes of companies.
- Under Section 148(2) the Government may direct a cost audit for covered companies above prescribed net worth or turnover.
- The cost auditor is a cost accountant appointed by the Board, with remuneration determined by the members in the prescribed manner.
- A person appointed as company auditor under Section 139 cannot be appointed for the cost audit.
- The cost auditor must comply with the cost auditing standards issued by the Institute of Cost Accountants of India with Central Government approval.
- The cost audit is in addition to the audit under Section 143.
- The cost auditor reports to the Board of Directors, not directly to the Central Government.
- The company must furnish the cost audit report to the Central Government within thirty days of receiving a copy, with full explanation of every reservation or qualification.
- The Central Government may call for further information and the company must furnish it within the specified time.
- Qualifications, disqualifications, rights, duties and obligations 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 for auditing cost records.
- 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 members appoint the cost auditor at the AGM. Fix: Remember Section 148(3): the Board appoints. Members only determine or ratify the remuneration.
- Allowing the statutory auditor to also do the cost audit. Fix: The first proviso to Section 148(3) bars a person appointed under Section 139 from the cost audit of the same company.
- Saying the cost auditor must be a chartered accountant. Fix: Section 148(3) requires a cost accountant. Section 141(1) is the statutory auditor's qualification.
- Believing the statutory auditor can also do the cost audit if he is qualified. Fix: The proviso to section 148(3) bars a section 139 auditor from being appointed for cost audit. Different persons are needed.
- Treating cost records and cost audit as the same requirement. Fix: Always answer both. Records come from Section 148(1) and audit from Section 148(2), with different thresholds.
- Using the current year's turnover instead of the immediately preceding financial year. Fix: Underline the year of the turnover. The Rules test the preceding year.
- Saying the cost auditor submits the report to the Central Government. Fix: Write the chain: cost auditor to Board, then company to Central Government within thirty days of receipt.
- Counting the thirty days from the balance sheet date or the end of the audit. Fix: Section 148(6) counts from the date the company receives a copy of the cost audit report.
- Writing that the Board fixes the cost auditor's remuneration. Fix: Write the two parts separately: Board appoints, members determine the remuneration in the prescribed manner.
- Saying the statutory auditor can also be the cost auditor. Fix: Recall the first proviso to Section 148(3). A person appointed under Section 139 cannot be appointed for the cost audit.
Exam tips
- Write the section number with the rule. 'Board appoints under Section 148(3)' scores better than a general statement.
- In a case question, check independence first. A link to the Section 139 statutory auditor is usually the planted issue.
- For CRA-2 date questions, show both calculations and then say 'whichever is earlier'. Marks go for the method.
- Keep three reports apart in your answer: appointment (CRA-2), the report to the Board, and the company's filing with the Central Government.
- In a short note, mention that the cost auditor must follow cost auditing standards and that the company must give all assistance and facilities.
- Quote section 148(3) and its first proviso word for word in spirit. Examiners look for the statutory auditor bar.
- In case scenarios, scan the facts for relatives, shareholdings, loans and services other than audit. These usually point to a section 141(3) disqualification.
- For a cost auditor versus statutory auditor comparison, cover qualification, appointing authority, standards followed, whom the report goes to, and that the cost audit is additional.