Institute's views on MCA's General Circular No. 18/2012

Institute's views on Ministry of Corporate Affairs General Circular No.
18/2012 dated 26th July, 2012 ......

<http://www.icwai.org/icwainew/docs/MCA-General-Circular-18-26_7_2012.pdf>

Ministry of Corporate Affairs vide their General Circular No. 18/2012 dated
26th July, 2012 has said that all cost auditors and the concerned companies
will be allowed to file their Cost Audit Reports and Compliance Reports for
the year 2011-12 [including the overdue reports relating to any previous
year(s)] with the Central Government in the XBRL mode, without any penalty,
upto 31st December, 2012. For this purpose, it has further said that

a) Filing of Cost Audit Reports and Compliance Reports for the year 2011-12
[including the overdue reports relating to any previous year(s)] with the
Central Government in the XBRL mode is mandatory.

b) The applicable XBRL taxonomy, business rules, validation tools, etc. and
also the "Product Group" classification required for preparing the cost
audit reports and compliance reports as per the notified Cost Accounting
Records Rules, 2011 and Cost Audit Report Rules, 2011 are under preparation
and would soon be made available by the Ministry.

c) The actual date for enabling XBRL filing will be intimated separately.

In connection with the provisions contained in the relevant Rules read with
the aforesaid Circular, the following may be noted:

(i) Rule 5 of the Companies (Cost Audit Report) Rules, 2011 says that the
Cost Auditor shall forward his cost audit report to the Central Government
within 180 days from the close of the company's financial year to which the
report relates. Rule 7 prescribes that the Annexure to the cost audit report
shall be approved by the Board of Directors.

(ii) Similarly, Rule 6 of the Companies (Cost Accounting Records) Rules,
2011 says that every company shall submit compliance report to the Central
Government within 180 days from the close of the company's financial year to
which the report relates. Rule 7 prescribes that the Annexure to the
compliance report shall be approved by the Board of Directors.

(iii) The above time limit of 180 days has been prescribed for submission of
the cost audit report by the cost auditor and for submission of the filing
such reports for the financial year 2011-12 [including the overdue reports
relating to any previous year(s)], MCA vide their General Circular No.
18/2012 dated 26th July, 2012 has extended this period of 180 days to 31st
December 2012.

(iv) MCA is yet to notify the applicable XBRL taxonomy, business rules,
validation tools, etc. and also the "Product Group" classification required
for preparing the cost audit reports and compliance reports.

(v) In view of above, audit of cost records, approval by the Board, and
filing of cost audit report & compliance report with the Central Government
should be completed by 31st December 2012.