9911796707
TMI Blog2024 (5) TMI 279X X X X Extracts X X X X X X X X Extracts X X X X ..... is concluded that the EP, EQCR Partner and the Audit Firm have committed Professional Misconduct as defined in the Act, as below: a) The Audit Firm Mis Dhiraj Dheeraj and the EP CA Piyush Patni committed professional misconduct as defined by Section 132(4) of the Companies Act, 2013, read with Section 22 and Clause 5 of Part I of the Second Schedule of the Chartered Accountants Act, 1949 (No. 38 of 1949) as amended from time to time, which states that a CA is guilty of professional misconduct when he fails to disclose a material fact known to him which is not disclosed in a financial statement, but disclosure of which is necessary in making such financial statement where he is concerned with that financial statement in a professional capacity . This charge is proved as the Audit Firm and EP failed to disclose in their report the material non-compliances the Company. b) Mis Dhiraj Dheeraj and CA Piyush Patni committed professional misconduct as defined by Section 132 (4) of the Companies Act, 2013, read with Section 22 and Clause 6 of Part I of the Second Schedule of the Chartered Accountants Act, 1949 (No. 38 of 1949) as amended from time to time, which states that a CA is guilty o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... attention to any material departure from the generally accepted procedure of audit applicable to the circumstances . This charge is proved since the Auditor failed to conduct the audit in accordance with the SAs but falsely reported in their audit report that the audit was conducted as per SAs. f) Mis Dhiraj Dheeraj, CA Piyush Patni and CA Pawan Kumar Gupta committed professional misconduct as defined by Section 132 (4) of the Companies Act, 2013, read with Section 22 and Clause 8 of Part I of the First Schedule of the Chartered Accountants Act, 1949 (No. 38 of 1949) as amended from time to time, which states that a CA is guilty of professional misconduct when he fails to communicate with outgoing auditor . This charge is proved since the Auditor failed to accept the audit in accordance with the law. Thus it is concluded that the charges of professional misconduct in the SCN are established based on the evidence in the Audit File, the audit reports on the standalone financial statements for the FY 2018-19 dated 13th August 2019 and the submissions made by the Auditor, and the Annual Report of Reliance Home Finance Limited for the FY 2018-19. Penalty and sanctions - HELD THAT:- Sec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the auditor of RHFL for FY 2018-19. The Director General of Corporate Affairs (DGCoA), Ministry of Corporate Affairs (MCA), Government of India, vide its letter dated 29.05.2020 informed the National Financial Reporting Authority (NFRA) that PW had filed a report to MCA under section 143(12)[ Under section 143(12) of Companies Act, 2013 auditor is required to report any fraud identified in the company] of the Companies Act, 2013 (the Act) on 03.06.2019. PW then resigned from the audit on 11.06.2029, without issuing an audit report for FY 2018- 19. Mis Dhiraj & Dheeraj were appointed by the board of directors of RHFL on 29.06.2019 as statutory auditors of RHFL to fill the casual vacancy caused by the resignation of PW. Further, the Securities and Exchange Board of lndia (SEBI) vide its letter dated 21.03.2022 informed NFRA that Mis Dhiraj & Dheeraj had issued a qualified opinion for FY 2018-19 1 Under section 143(12) of Companies Act, 2013 auditor is required to report any fraud identified in the company. without making adequate disclosures in the audit report, including the impact of 'General Purpose Corporate Loans' (GPCL) on financial statements. 2) On examination of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the Risk of Material Misstatement (ROMM) due to fraud or error in respect of (a) RHFL 's loan disbursal (General Purpose Corporate Loans) to financially weak companies without appropriate business rationale, (b) Funds so disbursed being diverted/siphoned off to other group entities. b) The Auditor did not perform sufficient appropriate audit procedures in respect of verification of the company's assessment of (a) the going concern assumption, and (b) adequacy of the Expected Credit Loss (ECL) of Rs 278 crore on loans at amortised costs of n 6,259 crore, which included Rs 7849 crore of General Purpose Corporate Loans to credit impaired entities on which ECL was only Rs 173 crore. c) The Audit Firm accepted the audit engagement without complying with the relevant requirements of the Chartered Accountants Act, 1949. Apart from the above, the Auditor did not ensure an objective engagement quality review by the EQCR Partner, failed to adhere to quality standards, failed to evaluate the going concern basis of accounting, and failed to comply with the requirements of SA while reporting on the work of management's experts. d) The omissions and commissions of the Audito ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lending policy. The outstanding amount of GPCL as of March 31, 2019, amounted to Rs 7,849.89 crore as per the financial statements. These loans were stated as secured by a charge on the current assets of borrowers. The majority of the Company's borrowers had undertaken onward lending transactions and the borrowings from the Company were used, inter a/ia, for repayment of financial obligations by some of the group companies. The previous auditor PW reported issues with the recoverability, end use and business rationale of these loans. Order in the matter of Statutory Audit of Reliance Home Finance Limited for F.Y. 2018-19 Page 3 of27 As per the report filed by PW under section 143(12) of the Act, they did not receive a satisfactory response from RHFL regarding queries raised on these matters. 10) Following the information from DGCoA and SEBI, as described in the executive summary of this Order, we suo motu decided to examine the audit evidence that led the Audit Firm to issue a qualified audit opinion. We called for the Audit File [Vide NFRA letter dated 24.11 .2021] and other information from the Audit Firm on 22.03.2022. After two extensions, the Audit Firm submitted the Aud ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... SES AND VIOLATIONS 13) The major basis for charges in the SCN included client acceptance without complying with requirements of the law, failure to examine the merits of the significant matters reported by the previous auditor, use of management's experts in violation of SA 500 [SA 500, Audit Evidence], failure in the evaluation of the Going Concern and Expected Credit Loss (ECL) on loans, and absence of objective review by the EQCR Partner. 14) Replies of the Auditor to the charges in the SCN are examined and discussed under the following broad categories. Only the violations/actions/omissions proved to result in one or more professional misconduct as per the articles of charges in the SCN are covered in this Order. C.1. Acceptance of the Audit Engagement C.2. Significant Matters Reported by the Previous Auditor C.3. Evaluation of the Going Concern Assumption C.4. Verification of Expected Credit Loss (ECL) on Financial Assets. C.5. Modification of the Audit Opinion on the Financial Statements. C.6. Use of the work of Management's Experts and Auditor's Expert C.7. Engagement Quality Control Review (EQCR) C.8. Compliance with SA 230 [SA 230, Audit Docu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... letters lack reliability and evidentiary value. More importantly, being qualified chartered accountants bound by the Code of Ethics and SAs, the Auditor knows very well that the engagement cannot be accepted without first communicating with the previous auditor. b) The following chronology of events makes it clear that the Audit Finn accepted the engagement before communication with the previous auditor and commenced the audit without waiting for a reasonable time for a reply from the previous auditor. Date of Communication Event/Correspondence 11.06.2019 PW resigned as statutory auditor of RHFL. 28.06.2019 RHFL Board resolution [As mentioned in the NOC letter of the Audit Firm.] for appointing Mis Dhiraj & Dheeraj 29.06.2019 Letter of appointment given by the Board. 01.07.2019 Engagement Acceptance letter given by Dhiraj & Dheeraj to RHFL. 02.07.2019 Dhiraj & Dheeraj sent request for NOC to PW. 03.07.2019 Audit planning meeting between the Engagement Team (ET) and RHFL. 05.07.2019 PW sent NOC to Dhiraj & Dheeraj. c) Further, the work papers (WP) in the Audit File [WPs 'J.4. K.3. Minutes of Planning Meeting with Team', "KA. Minutes of Planning Meet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... udit Firm and the EP are guilty of professional misconduct in terms of Clause 8 of Part-I of the First Schedule to the Chartered Accountants Act, 1949, paragraph 12(b) read with paragraph A21 of SA 300, paragraph 28 & 30 of SQC 1 and the Audit Firm's policy for accepting the Audit Engagement. 19) It is the admitted position [Paragraph B.7.5 of the Reply to the SCN by the Audit Firm] that the EQCR Partner participated in the planning meeting and the meeting where engagement acceptance was discussed and concluded. As explained above, both meetings were conducted before the receipt of NOC. Yet, the above violations remained unnoticed by the EQCR Partner. This shows the absence of due diligence and objective review required by SA 220. 20) We note that in a disciplinary case [As per the decision cited in the Code of Ethics 2009, issued by ICAI (S.N. Johri vs. N.K. Jain - Page 1042 of Vol.IV of the Disciplinary Cases - decided on 13th, 14th & 15th September 1973)] of ICAI, where a chartered accountant commenced the work of audit on the very day he sent a letter to the previous auditor the Disciplinary Council of I CAI had held that he was guilty of professional misconduct. The appo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ived by the Auditor, PW referred to its letter dated 18.04.2023 issued to RHFL. This letter contained the basis for the reporting of fraud by PW. Neither this letter nor a complete examination of the matters covered in this letter is found in the Audit File. b) Also, the management response to the queries raised by PW was not documented in the Audit File. The EP submitted the response of the management along with the replies to the SCN. On perusal of this letter, we find that it did not contain all the details which were part of PW's letter dated 18.04.2023. According to PW's letter (which we obtained from PW), in the financial year 2018-19, the GPCL had increased from approximately Rs.900 crores to approximately Rs 7900 crore. The letter also included a list of GPCL borrowers, tested by PW on a sample basis, and the queries raised [The key issues regarding GPCL included absence of business rationale for sanction of loans, issues in the internal control mechanism on sanctioning and disbursal of loans, procedures followed to monitor the end use of loans and for assessing the recoverability of loans, existence of borrowers, etc. In respect of certain borrowers which had neg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ions. d) There is no documented discussion amongst the ET members with an emphasis on material misstatement due to fraud, including how fraud might occur.[Paragraph 15 and 44 of SA 240 and Paragraph 10 of SA 315] There is no documentation of the significant decisions reached in this regard [Paragraph 44 of SA 240]. In the limited WP [K.12. Fraud Meeting Discussion] available, nothing is mentioned about the impact of matters reported by PW on the risk of material misstatement due to fraud. The WP only contains a list of around 20 discussion points, some of which are not even relevant to the audit of RHFL, evidencing that there were no specific discussions on PW matters. e) It is the admitted position of the Auditor that they accepted the engagement knowing that there was a report under section 143(12) by the previous auditor. However, at the time of accepting the client itself, the Auditor concluded [In WP K.9.Client-Engagement Acceptance & continuance checklist] that there was no risk of material misstatement due to fraud. There is no evidence of a due examination in this regard. There is also no proper identification and assessment of the Risk of Material Misstatement due to f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g loans (GPCL). Later in the same work paper, the ET took less than three-fourths of the GPCL as the sample. The audit procedure performed is limited to verification of the arithmetical accuracy of the data given by the Company. Similarly, the Auditor contends that the evaluation of credit appraisal, authorization of loan disbursement, verification of end-use of funds, etc. was done on a test basis. However, sufficient substantive procedures have not been performed by the Auditor as discussed in detail in section C5 below. Further, the claim by the Auditor that impairment has been made on the specific loans identified by PW is unacceptable, since the Auditor's procedures for verifying the Expected Credit Loss (ECL) on these loans were grossly inadequate as explained in section C4 of this Order. j) As it is evident from the reply to the SCN, and as explained in pre-paragraphs, the Auditor has placed reliance only on enquiries with the management on several significant areas, including key observations of the previous auditor. However, as explained in paragraph A2 of SA 500, although inquiry may provide important audit evidence, inquiry alone ordinarily does not provide suffici ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a focus on possible fraud factors as prescribed in SA 240, which is absent in this case. Any prudent auditor can understand the indications that the Company has attempted to depict irrecoverable loans as recoverable, thereby materially misstating the financial statements. Also, there were possible instances of siphoning off of money, indicated by irrational business decisions, multiple layers of transactions and borrowers having insufficient resources. In the latter case, the scope of the examination is much deeper than the reasonable assurance expected from a statutory auditor and hence called for specialised investigations. Until such investigations are completed, the Auditor could not be in a position to conclusively rule out the reported fraud. However, neither the Auditor suggested any such investigations to the Company nor the company suo motu undertook any such examinations. Instead, the Company acquitted itself of the allegations and the Auditor agreed to the views of the Company without the required examination, as explained in the above paragraphs. Such actions of the Auditor amount to gross negligence since the matter involved was material and pervasive to the financial ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g assumptions (paragraph 16 (c) of SA 570). 29) The minutes of the meeting with management recorded the management's views that the above events do not cast a material uncertainty. However, there is no further independent examination by the Auditor of these contentions of the management, as required by paragraph 16 of SA 570. Though the ET obtained the cash flow forecast prepared by the management, it did not perform any audit procedure to evaluate the reliability of the underlying data and adequacy of the assumptions. The ET neither obtained nor analysed any detailed maturity profile (fortnightly and monthly) of assets and liabilities over the next 12 months to support the forecast given by the company nor did they examine the probability of the positive outcome of restructuring of loans and ICA (Inter-Creditor Agreement) (paragraph 16(b) of SA 570). 30) As per paragraph 18 of SA 570, a material uncertainty exists when the magnitude of its potential impact and likelihood of occurrence is such that, in the auditor's judgment, appropriate disclosure of the nature and implications of the uncertainty is necessary for the fair presentation of the financial statements. Thus, o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tions and the mitigation plan. The disclosure made by the Company neither discussed the details of financing arrangements such as the magnitude, timelines, the availability of refinancing etc. The Independent Auditor's Report included an 'Other Matter' paragraph on going concern which stated that the liquidity mismatch was resulting in delayed payment of bank borrowings and the Company's ability to meet its obligation was dependent on "material uncertain" events. This is not in line with the Company's disclosure since the disclosure did not describe any of the events as "material uncertain". Such inconsistencies and non-compliance with SAs show that the audit opinion is without adequate basis. 33) Thus, when events that may cast significant doubt on the going concern status are present, the auditor must perform further audit procedures as mandated by SA 570 to rule out the existence of material uncertainty. No such procedures are performed by ET. The disclosures made in the financial statements and the reporting by the Audit Firm are incomplete and, therefore, misleading. Hence, there is no adequate basis for the Audit Firm to conclude that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ting to ECL. The Auditor failed to show sufficient appropriate evidence to support the assertions in the financial statements relating to ECL. In the absence of adequate evidence, we conclude that the following omissions and commissions, as conveyed in the SCN, contributed to the absence of verification of ECL. a) There is insufficient evidence of substantive procedures performed to verify the ECL model. The WP ["2.ECL MODEL DEVELOPMENT.pdf] available in this regard is a copy of the calculations of ECL as per the Company's ECL model. As per the model, the Company classifies an asset into one of the three stages solely based on Days Past Due (DPD) status. There is no consideration of the qualitative criteria for classifying loans. This is not in conformity with paragraph 5 .5 .11 of lnd AS 109, which states that if "reasonable and supportable forward-looking information is available without undue cost or effort, an entity cannot rely solely on past due information when determining whether credit risk has increased significantly since initial recognition. However, when information that is more forward-looking than past due status (either on an individual or a collecti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9 and Ind AS 107. Such loans were originated credit impaired and hence were required to account with a carrying value reflecting the lifetime expected credit losses as per Ind AS 109. A few instances noticed, to gauge the extent of misstatements, are given below. i) RHFL sanctioned loans of Rs. 50 crore to Hirma Power Ltd, and ~55 crore to Tulip Advisors Private Ltd in FY 18-19. The total exposure of these two Companies was shown as Rs 444.67 crore as per the ECL workings [WP l.ECL FRM disclosure working 19Aug2019].. As per the audit documentation[WP 4.10.CAM], these two companies had virtually no revenues and were in losses. The net worth was completely eroded, and the loans were disbursed without any security, having no credit rating and after waiving all the requirements for a corporate loan as per the company's policies. Still, these loans were classified under stage 1, with a nominal ECL of Rs 41 lakh [Sheet Mar' 19 of WP I.ECL_FRM disclosure working 19th Aug 2019] . These loans were evidently credit impaired right from the time they were made. As per Ind AS 109, financial assets that are credit-impaired upon initial recognition are categorized within Stage 3 with a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owever, there is no assessment of the consequences of this material weakness on ECL calculations. There is also no separate test of the design, implementation, and operating effectiveness of internal controls on ECL as required by SA 540 and SA 315. g) The Company provided the percentages of average Probability of Default (PD) rates, Loss Given Default (LGD) rates, and the ECL amount. However, other than checking the arithmetical accuracy of the calculations [WP 4.14, 4.2, 4.3 etc.] there is no examination by the ET. Even the basic tests or questions to the management were not raised in evaluating the ECL. For instance, there is no evidence of: i) How the Auditor ruled out the possible management bias in the ECL model and calculations. ii) The Company's and borrower's (group companies) going concern were affected by significant uncertain events. There is no evidence of how these events were factored into the working of PD. As it appears from the WPs, the Company has simply adopted the average PD and LGD calculated in the previous year without considering any adjustments for the forward-looking information reflecting the uncertainties at present. The Audit Firm did not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of $65,000. C.5. Modification of the Audit Opinion on the Financial Statements 40) The Auditor issued a qualified opinion on the basis that sufficient appropriate audit evidence was not available to ascertain the recoverability of principal and interest, including the time frame of recovery, of overdue amounting to Rs 566.30 crore of General Purpose Corporate Loans as on March 31, 2019. In this regard, the EP and the Audit Firm were charged with failure to consider the pervasiveness of GPCL transactions and balances while forming the audit opinion, thereby violating SA 330 [SA 330, The Auditor's Responses to Assessed Risks] and SA 705(Revised). 41) In their reply to the SCN, the EP and the Audit Firm reiterated their conclusions recorded in the Audit File and stated that "Our concern on the GPC loan was primarily regarding non-availability of audit evidence to ascertain recoverability of principal and interest including time.frame of recovery of overdues of GPCL as on March 31, 2019. Since this matter was isolated and specific to recovery of overdues of GPCL, in our professional judgement had concluded that our audit report should be qualified in respect of this matter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tions in the approval process, discrepancies in credit appraisal, no recovery steps despite defaults in repayment, non-monitoring of borrower accounts post-disbursal, etc. The management has failed to provide any explanations regarding the recoverability of the entire outstanding balance. So, there is not enough basis for the ET to conclude that the absence of sufficient evidence is limited only to the principal and interest outstanding on some loans out of this population. e) Note no. 4 of the financial statements contain the disclosures about the loan balances where the company has asserted that the loans and other credit facilities given to customers are secured. However, the ET had observed that in many cases loans were disbursed without the creation of security. This impacts recoverability and shows the Auditor's agreement with the misleading assertion by the Company. f) Overall materiality was fixed at Rs 15.34 crore. The principal overdue and interest overdue were much above the materiality level. Since there is no evidence for the recoverability of GPCL, the accounting assertions of valuation of the loans amounting to at least Rs 945.58 crore, accuracy of interest o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ompliance with the requirements of SA 500 and SA 620 does not arise. We observe that the submissions are contradictory to the facts, as explained hereafter. a) Note 54 discloses a material matter that has a pervasive effect on the financial statements. The Auditor concurred with this note explicitly in their audit report as explained in the previous paragraphs of this Order. As per note 54 quoted above, the basis for ruling out fraud, reported by PW under Section 143(12) was, (a) the Company'~ examination of the matter and (b) an "in-depth examination" by the management's experts. In its audit report under CARO 2016, the Audit Firm drew attention to note 54 of the financial statements. These facts show that the EP had used the work of the legal experts, without which he cannot endorse a statement made by the company regarding the work of the management's experts. b) However, the Auditor admitted that they had not relied on management's experts. Also, as evidenced by the Audit File and as admitted, the EP has not complied with the prerequisites for the use of the work of an expert. As far as the stated examination by the Company, we have already conclud ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rt. Hence, the charges in paragraph 44 above are proved. C.7. Engagement Quality Control Review (EQCR) 47) The EQCR Partner and the Audit Firm were charged with failure to ensure compliance with SA 220 [SA 220, Quality Control for an Audit of Financial Statements] and SQC-1 because of the EQCR Partner's failure to objectively evaluate the significant judgments and conclusions of the ET. The EQCR Partner failed to conduct the review on time at appropriate stages during the engagement (paragraph 66 of SQC 1) and document procedures or observations on any of the significant matters arising during the audit as required by SA 220. The WPs [Contained in the Audit File's folder namely "J. Engagement Quality Control Review"] are limited to a checklist and the EQCR partner's blind agreement to the conclusions of the ET. 48) In response to the above charges, the EQCR Partner stated that he was involved in the evaluation of significant judgements made by the ET through participation in planning and audit committee meetings, discussion with the EP, review of certain documents and documentation as per the checklist provided by the Audit Firm. He further claimed that th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2.01.2015], the US Regulator, charged Grant L. Hardy (CPA) for his failure in connection with his role as Engagement Quality Reviewer ('EQR' hereafter) in the audit of financial statements of some of the issuer clients and noted that "Hardy violated PCAOB Auditing Standard No. 7, Engagement Quality Review ("AS 7") by providing his concurring approval of issuance without performing with due professional care the EQRs required by this standard for the Firm's audits of COPsync and Forever Green's December 31, 2010, financial statements and AEG's June 30, 2011, financial statements." For this misconduct, PCAOB censured the EQR, barring him from being an associated person of a registered public accounting firm for 1 year. 52) PCAOB in the matter of Cheryl L. Gore, CPA and Stanley R. Langston, CPA, charged [PCAOB Release No. 105-2021-020 December 14, 2021] Stanley R. Langston (CPA) for his failure in connection with his role as Engagement Quality Reviewer in the audit of financial statements of some of the issuer clients and noted in its order dated 14.12.2021 that "Langston violated AS 1220, Engagement Quality Review, by providing his concur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ofessional misconduct as defined by Section 132(4) of the Companies Act, 2013, read with Section 22 and Clause 5 of Part I of the Second Schedule of the Chartered Accountants Act, 1949 (No. 38 of 1949) as amended from time to time, which states that a CA is guilty of professional misconduct when he "fails to disclose a material fact known to him which is not disclosed in a financial statement, but disclosure of which is necessary in making such financial statement where he is concerned with that financial statement in a professional capacity". This charge is proved as the Audit Firm and EP failed to disclose in their report the material non-compliances the Company made as explained in sections C.2 to C.6 above. b) Mis Dhiraj & Dheeraj and CA Piyush Patni committed professional misconduct as defined by Section 132 (4) of the Companies Act, 2013, read with Section 22 and Clause 6 of Part I of the Second Schedule of the Chartered Accountants Act, 1949 (No. 38 of 1949) as amended from time to time, which states that a CA is guilty of professional misconduct when he "fails to report a material misstatement known to him to appear in a financial statement with which he is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onal misconduct when he "fails to invite attention to any material departure from the generally accepted procedure of audit applicable to the circumstances". This charge is proved since the Auditor failed to conduct the audit in accordance with the SAs as explained in paragraphs C.1 to C. 7 above but falsely reported in their audit report that the audit was conducted as per SAs. f) Mis Dhiraj & Dheeraj, CA Piyush Patni and CA Pawan Kumar Gupta committed professional misconduct as defined by Section 132 (4) of the Companies Act, 2013, read with Section 22 and Clause 8 of Part I of the First Schedule of the Chartered Accountants Act, 1949 (No. 38 of 1949) as amended from time to time, which states that a CA is guilty of professional misconduct when he "fails to communicate with outgoing auditor". This charge is proved since the Auditor failed to accept the audit in accordance with the law as explained in paragraphs C.1 above. 56) Therefore, we conclude that the charges of professional misconduct in the SCN, as detailed above, are established based on the evidence in the Audit File, the audit reports on the standalone financial statements for the FY 2018-19 date ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
