Controller & Auditor General Of India
Sub: For error in the report of CAG in respect of TAR signed by CAs in excess of limit prescribed by ICAI
Dear Sir,
First of all, let me thank you for the efforts taken by you to find “How many CAs have signed report in excess of limit prescribed by ICAI as it adversely affect quality.
LIMIT PRESCRIBED BY ICAI
The ICAI has prescribed limit of 45 Tax audit / partner excluding report signed u/s 44AD.In case of firm , “limit of firm” will be 45 Tax audit / partner excluding report signed u/s 44AD. In other words, in case of a partner, it is possible that one partner can sign all the tax audit report of the firm( as allowed by the Chartered accountants Act).
ERROR IN REPORT OF CAG
1) CAG had not considered report signed by CAs u/s 44AD separately.
2) CAG has not considered the limit of the firm & has considered the limit of the individual partner.
As a result, the no of CAs signing the report within limit is expected to be deceased by many fold.
As per the report, more than 19% CAs have signed in excess of limit. However, it is expected that only 3% CAs have signed report in excess of the limit (Please see analysis below).
NEGLIGENCE OF CAG
CAG is a big brother of the ICAI. ICAI has been formed under the Act passed by the parliament.
1) Before coming out such report, have CAG consulted ICAI? If not, why CAG did not consulted ICAI. This report put a question marks the report of CAs in general.
2) How can CAG report contain such errors?
3) This report of the CAG has downgraded the report of CAs in general without sufficient cause.
4) CAG has neither provided the opportunity of being heard to ICAI nor to individual CAs
Why CAG have denied natural justice of opportunity of being heard?
Suggestion of CA N More,
"Bring 60 TAR limit/ partner in IT act so that IT dep can look into issue".
ONLY 3% CAs ARE EXPECTED TO SIGNED TAR IN EXCESS OF LIMIT:
1) More than 81% CAs issued 45 or less TAR.
2) More than 16% CAs issued 100 or less TAR. As report issued u/s 44AD are not to be included in limit of 45 & as, i think, IT dep has not segregated report issued u/s 44AD & other tax audit reports u/s 44AB, in my views, these CAs are expected to issue TAR in limit of 45 excluding TAR issued u/s 44AD.
3) It means only 3% CAs is expected to have violated limit.
CA Nitesh More
List of CAs issuing more than 400 TAR; 18.87% CAs issued more than 45 Tax Audit Report- CAG
Table 3.1: Stratification of total TARs issued by CA for AY 2013-14
| Range of TARs issued | Total Number of Accountants | Percentage of Total Accountants |
| 1-45 | 53,463 | 81.13 |
| 46-100 | 10,838 | 16.45 |
| 101-200 | 1,364 | 2.07 |
| 201-300 | 166 | 0.25 |
| 301-400 | 45 | 0.07 |
| 401-500 | 10 | 0.02 |
| 501-1000 | 11 | 0.02 |
| > 1000 | 1 | 0 |
| Total Accountants | 65,898 |
Table 3.2 shows top 22 CAs who issued more than 45 TARs for AY 2013-14.
Table: 3.2 showing CAs issuing more than 400 TAR for AY 2013-14
| Chartered Accountants | Membership Number | Number of TARs |
| 1. Pralay Chakraborty | 059736 | 2,471 |
| 2. Partha Pratim Mukhopadhyay | 056366 | 990 |
| 3. R Muralidharan | 024060 | 796 |
| 4. Rajesh Kumar Gupta | 074194 | 640 |
| 5. Swapan Acharyya | 062815 | 638 |
| 6. D Sundararajan | 010150 | 619 |
| 7. B C Vadivel | 206700 | 612 |
| 8. Raj Hans | 087767 | 586 |
| 9. Samir Pushpvadan Gandhi | 039251 | 551 |
| 10. Navin Agarwal | 078175 | 522 |
| 11. Poulose Shaji | 022909 | 513 |
| 12. A Kulathooran Pillai | 018792 | 510 |
| 13. Sukdeb Haider | 051185 | 494 |
| 14. Chetan Premchand Shah | 031239 | 487 |
| 15. P Ramalingam | 019516 | 478 |
| 16. Arun Kumar | 097929 | 461 |
| 17. S Vairavanathan | 004736 | 457 |
| 18. Radhakanta Das | 062863 | 428 |
| 19. Suresh Kumar Goyal | 084153 | 417 |
| 20. Hetal Bhailalbhai Dhamelia | 119864 | 415 |
| 21. TS Ventakaraman Lakshmi | 022214 | 414 |
| 22. Jai Bhagwan Mittal | 084512 | 401 |
Warm Regards
"Team" CA.Nitesh More
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