BCAS President CA. Sunil Gabhawalla's Message for the Month of December 2018
Immediately after the completion of the deadline for transfer pricing audits, we now have one more deadline for uploading of GST Audit Reports by end of December. This would be the first time that the members would be undertaking the assignments for GST Audit for their clients. While the statutorily prescribed GST Audit Report primarily anchors itself around the auditors providing a true and correct view of various reconciliations listed in the Format, the Technical Guide suggests a much larger involvement/expectation from the GST Auditors in terms of compliance with various legal provisions. It is therefore important that the scope of audit be clearly understood and communicated to the clients at the outset. It would also be fruitful to have proper engagement letter spelling out this scope and the inherent limitations of any assurance assignment. Last but not the least, the fees charged should be commensurate to the work done and the complexity of the assignment and the risks involved.
While as professionals, we would gear up for the new responsibility cast upon us, it is also important for the Government to act fast. Though the formats are prescribed since quite some time, the portal is still not ready to receive the reports. It would be appropriate for the Government to expedite this process and also announce an extension well in advance since the time left for uploading is obviously very limited.
In a recent judgement, the Supreme Court held that action can be taken against chartered accountants if their conduct brings ‘disrepute’ to the profession even if such an action was not related to professional work. This decision reinforces the extensive regulatory powers of the Disciplinary Committee of the ICAI in handling various complaints against the members. At the same time, it acts as a wakeup call for professionals who are expected to not only ensure that their behavior in the profession or otherwise is in compliance with laws but also follow accepted norms of social behaviour.
The year 2018 was a crucial one for the profession. In the earlier months, the Nirav Modi Scam brought to forefront the expectations of various stakeholders from the profession. As more and more financial failures came to limelight, the role of chartered accountants was widely discussed in the media reports. In the meantime, NFRA as an independent regulator to oversee the auditing profession was also set up. While we may have our own lines of defense, it is also time to wake up to the expectations of the stakeholders.
It is in the above context that the Council Elections become very important. I am sure that each one of you will go out to vote for ICAI elections. It may also be useful to make the best use of the preferential voting mechanism and vote for as many deserving candidates in orders of preference.
The year 2018 is about to end, it’s time to take stock of all that was good and relish those memories. It is also time to take stock of all that did not end up well and analyse the reasons for the same. If required, it could also be an opportunity to strategise and find solutions for improvements in the future. Here’s wishing You All a Merry Christmas and a Happy and Joyous New Year-2018! I urge members to take a well-deserved break and spend quality time with their near and dear ones to start afresh with renewed vigour for the New Year.
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With kind regards
CA. Sunil Gabhawalla