To,
The Institute of Chartered Accountants of India (ICAI)

Subject: Constructive feedback and rationalisation proposals for CA Final Paper 6 (Integrated Business Solutions) and core curriculum alignment


Dear Sir/Madam,


I am writing as a practising member of the Institute and an educator involved in training CA Intermediate and CA Final students. I fully support ICAI’s vision of making the CA curriculum more application‑oriented and globally benchmarked.

The purpose of this memorandum is to share ground‑level feedback on CA Final Paper 6 – Integrated Business Solutions (IBS) and to offer some practical, moderate suggestions. These suggestions aim to make the examination more fair, easier to conduct, and more relevant to the realities of today’s corporate and practice environments.

 

1. Current operational and structural challenges in IBS

IBS, as a four‑hour open‑book case‑study‑based paper drawing on FR, Audit, DT, IDT, Law, AFM and SCPM, is a very progressive idea in principle. In practice, however, students are facing some serious issues:

  • “Mini‑library” logistics

Because the paper can draw from almost the entire Final syllabus (and parts of SPOM), students feel compelled to carry large numbers of books and notes into the exam hall, often in trolley bags. This causes space constraints on desks, longer security checks, and operational difficulties at many centres.

  • Uneven playing field

Students who can afford multiple commercial compilations and extensive notes are at an advantage over those relying mainly on ICAI material. Even capable students often lose valuable time in the exam just searching through piles of books to locate the correct provision or concept.

  • Redundant focus on writing skills

Written expression and presentation are already thoroughly tested in multiple papers at the Foundation, Intermediate and Final levels. IBS does not need to become another examination of long‑form descriptive writing. Its core purpose should be to assess a candidate’s ability to apply and connect concepts from different subjects to resolve complex, realistic business situations.

  • Group asymmetry

IBS sits in Group II, but assumes advanced understanding of Group I subjects such as Financial Reporting and Advanced Financial Management. This puts candidates attempting only Group II at a structural disadvantage, as they are effectively tested on competencies from papers they may not yet have cleared.

 

2. Operational risks of the tablet system

One proposal discussed has been to provide centre‑managed, returnable tablets pre‑loaded with ICAI study material. While the intention is noble—to standardise material and reduce the burden of carrying books—a hardware‑heavy approach brings several risks:

  • Capital and maintenance load

Procuring, tracking, charging, storing and periodically replacing thousands of tablets across centres nationwide would be costly and administratively demanding.

  • Technical vulnerabilities

Device freezes, crashes or battery failures during the exam could directly affect students’ performance and create grounds for grievances and disputes.

  • Environmental challenges

Ensuring consistent hardware performance in varied Indian conditions—heat, dust, humidity, power interruptions—is inherently difficult.

  • Duplication of existing digital infrastructure

ICAI already has strong digital platforms such as the Digital Learning Campus, the SPOM framework, the BoS Knowledge Portal and the BoS Mobile App for providing e‑learning and e‑books. Creating a parallel tablet ecosystem at examination centres would duplicate infrastructure rather than build on what already exists.

For these reasons, it may be wiser to follow the computer based software‑driven approaches used by leading international professional bodies, where open‑book content is delivered digitally within secure computer‑based exam platforms.

 

3. Insights from global best practices

Many international professional qualifications test integrated, multi‑disciplinary capability in a structured way:

  • Singapore CA Qualification – Integrative Business Solutions (IB)

The Singapore CA has a capstone module called Integrative Business Solutions, attempted only after candidates complete key technical modules in Financial Reporting, Assurance, Taxation and Business Value, Governance & Risk. It is an open‑book e‑examination, focused on business judgement and integrated application rather than pure recall.[eservices.isca.org]

  • ACCA – Strategic Business Leader (SBL)

ACCA’s SBL is a long, integrated case‑study exam that mirrors the role of a senior manager. It assesses technical knowledge together with professional skills such as analysis, strategy, communication and ethics, guided by detailed public blueprints and marking schemes so candidates clearly understand what is expected.[accaglobal]

  • CIMA / AICPA-CIMA – Strategic Case Study

CIMA’s Strategic Case Study is taken only after passing the three underlying objective test papers at that level. It checks how well candidates can apply their knowledge in realistic corporate scenarios, using a clearly defined competence framework.

  • ICAEW – Case Study and digital open‑book delivery

ICAEW runs its Professional and Advanced Level exams as computer‑based exams using dedicated exam software. In open‑book settings, students access a digital bookshelf or PDF viewer containing permitted texts directly within the exam interface, rather than carrying physical books or using separate devices. This removes logistics issues and ensures every student has the same clean electronic reference material.

These examples show that robust integrated assessment can be delivered via secure computer‑based exams, with standardised digital reference material, clear blueprints, and sequencing that treats the integrative paper as a true capstone.

 

4. Rebalancing the curriculum for a job‑centric market

In recent years, a clear majority of newly qualified CAs have tended to prefer corporate, consulting and industry roles over starting independent practice, due to salary levels, lifestyle considerations and the costs and risks of setting up practice. Our curriculum should reflect this reality, ensuring that we do not become overly skewed towards producing only tax‑heavy practitioners.[economictimes.indiatimes]

Globally, taxation is generally organised as one broad core paper, with deeper tax specialisations offered through electives:

  • The Singapore CA runs a unified Taxation module covering corporate tax, income tax, stamp duty and GST in a single paper.[isca.org]
  • ACCA has a single core Taxation (TX) exam, with Advanced Taxation (ATX) as an optional strategic‑level elective for those who want depth.
  • ICAEW’s Tax Compliance and Planning combines different tax heads within a single framework and is positioned as testing competence, not narrow specialist advisory work.[icaew]

By contrast, our current CA Final structure with separate full‑fledged Direct and Indirect Tax papers is more practice‑oriented than job‑oriented, and sits somewhat apart from this global pattern.

 

5. A six‑paper Final structure with a concluding capstone

To keep the Final level lean at six written papers while improving corporate relevance and global alignment, the following moderate restructuring is suggested:

  1. Strengthen Finance at Intermediate
    • Shift 50 marks of foundational Advanced Financial Management (AFM) content from CA Final down to CA Intermediate.
    • Merge this with the existing Financial Management syllabus to create a 100‑mark “Financial Management & AFM” paper at Intermediate.
    • This builds stronger finance skills earlier, which is valuable for job‑oriented roles and in line with how many global qualifications structure finance learning.[cimastudy]
  2. Create a combined Law & AFM paper at Final
    • At CA Final, introduce a 100‑mark paper comprising 50 marks of Corporate/Advanced Law and 50 marks of strategic AFM.
    • Law remains vital for both corporate roles (governance, compliance, contracts) and practice (company law advisory, regulatory work). AFM at Final can focus on higher‑order topics like valuation, capital structure and strategic financial management rather than basics already covered at Intermediate.
  3. Re‑position SCPM and Strategic Management
    • Position Strategic Cost & Performance Management (SCPM) as a core Final‑level paper, integrating key elements of Strategic Management currently at Intermediate.
    • Within this paper, ICAI may earmark a portion (for example, 50 marks) for an advanced module closely linked to IBS‑type skills, such as Advanced Performance Management or advanced management reporting.
  4. Consolidate taxation at Final
    • Combine Direct Tax and Indirect Tax into a single, well‑structured Final paper (for example, “Direct Tax Laws & Indirect Taxation” as one combined subject), with clear internal weightage and boundaries.[eservices.isca.org]
    • Candidates who wish to specialise in tax practice can pursue advanced tax electives through SPOM or the elective Final paper, and through post‑qualification courses.
  5. Use IBS as a capstone, computer‑based exam
    • After a student has passed both Final groups, require them to appear for a concluding IBS Capstone examination.
    • This Capstone can be fully computer‑based, with caselets and MCQs or structured tasks, and with ICAI‑issued digital reference materials embedded in the exam software, similar to Singapore’s IB and ICAEW’s open‑book approach.[isca.org]
    • In this configuration, IBS becomes a true capstone, testing cross‑functional synthesis only after technical competence in all core subjects has been demonstrated.

A possible high‑level blueprint (illustrative) could look like this:

CA Intermediate

  • Group I
    • Paper 1: Advanced Accounting
    • Paper 2: Corporate and Other Laws
    • Paper 3: Taxation
  • Group II
    • Paper 4: Cost & Management Accounting
    • Paper 5: Auditing and Ethics
    • Paper 6: Financial Management & AFM

CA Final

  • Group I
    • Paper 1: Financial Reporting (FR)
    • Paper 2: AFM & Advanced Law
    • Paper 3: Advanced Auditing, Assurance & Professional Ethics
  • Group II
    • Paper 4: Direct Tax Laws & Indirect Taxation (single combined paper)
    • Paper 5: Strategic Management & SCPM
    • Paper 6: Elective (Advanced Tax, International Tax, AI, Risk Management, Sustainability Reporting, etc.)

Capstone (Post‑Final)

  • Integrated Business Solutions (IBS) – computer‑based Capstone exam, attempted after passing both groups, focused purely on integrated application and business judgement.

The existing Self‑Paced Online Modules (SPOM) framework can then be used more deliberately for specialised technical electives (Risk Management, Sustainable Development and Sustainability Reporting, International Taxation, Valuation, Forensic Accounting, etc.) and for life‑skills and professional‑skills modules (Constitution & Art of Advocacy, Psychology & Philosophy, Entrepreneurship, Artificial Intelligence, Digital Ecosystem and Controls).

 

6. Value for key stakeholders

Such a structure responds to three clear realities: the growing preference for corporate careers among new CAs, global movement towards integrated capstone assessments, and the need to prioritise analytical business judgement over rote reproduction.

  • For corporate‑bound candidates

A consolidated tax structure, stronger Law, Costing and AFM exposure, and a capstone IBS examination offer a balanced, job‑ready skill set: financial analysis, governance, broad‑based tax understanding and the ability to tackle real business cases.

  • For future practitioners

Students still build strong foundations in audit, tax, law and performance management, while advanced specialisations are channelled through electives and post‑qualification learning. The capstone IBS format helps them practise the multi‑disciplinary thinking required for complex client advisory and litigation support.

I submit these suggestions with full respect for the Institute and with the sole intention of supporting ICAI’s efforts to keep the CA qualification modern, rigorous and globally respected.

Yours faithfully,

CA. Parag Gupta

Ph.: 9891432632