Quality of XBRL filing certified by Professional members. - Companies Law - 33/2012

General Circular No: 33/2012 No. HQ/MCA/Digitized/ARBS/2009-Pt2 Government of India Ministry of Corporate Affairs 5th Floor, "A" Wing, Shastri Bhawan, Dr. R.P. Road, New Delhi - 110001 Dated: 16.10.2012 To The President Institute of Chartered Accountants of India, Institute of Company Secretaries of India and Institute of Cost Accountants of India Subject: Quality of XBRL filing certified by Professional members. Sir, You are aware that XBRL filing of financial statements by a select class of companies for FY 2010-11 was mandated vide Ministry of Corporate Affairs Notification GSR No: 748(E) dated 05.10.2011 . The e-forms were duly certified by CA/CS/CWA professionals for their completeness and correctness in representation with respect to audited financial statement of the company. 2. A random scrutiny of XBRL filing of financial statements by few companies to MCA for FY 2010-11 reveals significant variations in disclosures in published results and the XBRL filings due to incorrect' mapping of disclosures. It has been observed that few disclosures were mapped/tagged with incorrect accounting concept despite availability of appropriate element in taxonomy. It has also been observed that. provisions of "Block Text tagging" and/or "Footnote" have been inappropriately used to report disclosures, like subsidiary details, related party transactions, Director's Report, etc., even when appropriate elements were available in the taxonomy for such disclosures. Few instances of "incorrect tagging of XBRL documents are provided at Annexure-I. 3. Such filing are inaccurate and do not adequately represent true and fair view of the state of affairs of the company as per Section 211 of the Companies Act, 1956 . Such XBRL filings, apart from being misleading, also dilute the effectiveness of XBRL for stakeholders' usage relating to the companies. It is unfortunate that professionals have certified the authenticity of such incorrect data, for which they are liable to be penalized. Such lapses defeat the very purpose of introducing XBRL filings 'which are meant to elicit more detailed and refined information as to the affairs of companies. Please note that XBRL filings are being minutely scrutinized to see if similar mistakes also appear in a larger sample. 4. It is bounden duty of Institutes to direct its members to take necessary steps to improve the quality of XBRL filing for FY 2011-12 to be undertaken by its members. The Institute may conduct further trainings, issue guidelines, etc so that such quality related issues are appropriately resolved. 5. This may be accorded high priority. Yours faithfully, (Pankaj Srivastava) Director Encl: As above Annexure-1 GENERAL XBRL FILING ERRORS Errors Observation Cash Flow Statement not tagged The Cash Flow Statement for FY 2010-11 is available in the Audited Financial Statements (PDF file). However, the same has not been tagged in XBRL financial statements filed at MCA portal. Information of all subsidiaries not provided in XBRL financial statements Information about one Subsidiary has been tagged 'n XBRL financial statements whereas the Company had nine Subsidiaries. Information of all related party transactions not provided in XBRL financial statements Related Party Disclosures have not been tagged in XBRL financial statement. Parenthetical (additional disclosures) information not tagged in XBRL financial statements Aggregate Market Value of Investments not provided by way of footnote. Additional information on Issued, Subscribed Paid up Share Capital not explained by way of footnote. Footnotes not tagged in XBRL financial statements. Footnotes on Share Capital, Secured Loan, Reserve and Surplus, unsecured loan-Fixed deposits, Investments, Fixed Assets, Security deposit, etc have not been tagged. Footnote on "Investments" has not been given. Different presentation in pdf and XBRL filings The Annual Report presented before the shareholders the figures were presented in Rs Thousands whereas in the XBRL documents the figures were provided in Rs. Lakhs. Incorrect usage of Footnote Director's Report provided by way of footnote whereas separate tags are available for tagging of Directors' Report. Similarly, for Auditors' Report, Significant Accounting policies, Unsecured Loan, Current Liabilities, etc Footnote has been incorrectly used. INCORRECT USAGE OF TAGS A. When appropriate taxonomy element is available Line Item Tag Used (label) Correct Tag (label) Secured Cash Credit from Banks Term Loan Working Capital Loans Banks Secured Investment in Quoted Equity Shares Unutilized Money Equity Securities Long Term Quoted Bad debts written off Other Provisions Created Bad debts Advances written off Investment (joint Venture) Equity securities long-term unquoted non-trade Investment joint ventures Power and fuel expenses Electricity expenses Cost power fuel Advertising and Brand marketing Travelling conveyance Advertising and promotional expenses Travelling and conveyance Legal professional charges Travelling conveyance Purchase/sale of Fixed Assets Purchase other Assets, Proceed disposal other assets Purchase tangible fixed Assets, Proceeds sale disposal tangible fixed assets B. Incorrect tagging/inaccurate disclosures Line Item Tag Used Correct Tag Remarks Stock Differential- (Decrease)/Increase Not tagged separately Increase decrease inventories Clubbed with 'Other expenditure'. Salaries, Wages Bonus Tagged as zero Amount is 92,539,039 It is a mandatory tag. Clubbed with 'Other expenditure'. Power, Fuel, Water Gas Tagged as zero Amount is 248,737,864 Clubbed with 'Other expenditure'. Manufacturing Cost Tagged as zero Clubbed with 'Other expenditure'. It is a manufacturing company RAW MATERIALS CONSUMED Opening Stock Not tagged Stock of Raw Materials, Opening Balance Given as part of footnote to 'Raw Materials Consumed' RAW MATERIALS CONSUMED Add: Purchases Not tagged Purchase raw materials during year RAW MATERIALS CONSUMED Less: Closing Stock Not tagged Stock of Raw Materials, Closing Balance Deferred Tax Liability (Net) Net Deferred Tax Assets Deferred Tax Liability Tagged with negative sign. Deferred tax liabilities(Net) Deferred tax liability depreciation Deferred tax asset other, Deferred tax asset VRS payment, Deferred tax asset provision for doubtful debts, etc Disaggregated disclosures all consolidated into 'Deferred tax liability depreciation'