Facts
of the Case
The
complainant, CA Ashish Chhabra, was the statutory auditor of M/s ROC Foods
Limited for nearly ten years and completed his term during Financial Year
2017-18. During the course of audit, disputes arose between the complainant and
the company regarding audit observations and pending professional fees. The
complainant indicated that a qualified audit report would be issued for
Financial Year 2018-19.
Subsequently,
the respondent, CA Neha Bansal, was appointed as statutory auditor of the
company for Financial Years 2018-19 to 2023-24. It was admitted on record that
prior to acceptance of the audit appointment, the respondent did not
communicate in writing with the complainant, who was the previous auditor, as
required under Item (8) of Part I of the First Schedule to the Chartered
Accountants Act, 1949 read with the Code of Ethics, 2009. Disciplinary
proceedings were initiated under Section 21A of the Chartered Accountants Act,
1949.
Issues
Involved
Whether
the respondent Chartered Accountant was guilty of professional misconduct under
Item (8) of Part I of the First Schedule to the Chartered Accountants Act, 1949
for accepting statutory audit appointment without prior written communication
with the outgoing auditor, whether reliance on the auditee’s instructions
absolved the respondent of ethical responsibility, and whether such conduct
warranted disciplinary action.
Petitioner’s
Arguments
The
complainant contended that the respondent accepted the statutory audit
assignment despite clear ethical requirements mandating prior written
communication with the outgoing auditor. It was argued that the respondent’s
conduct facilitated unethical change of auditor to avoid a qualified audit
report and undermined the safeguards intended to protect audit independence and
professional discipline. The complainant submitted that non-payment of
professional fees and allegations of mala fide intent by the company did not
dispense with the respondent’s ethical obligations.
Respondent’s
Arguments
The
respondent submitted that she was informed by the company that the complainant
had mala fide intentions and that the company had specifically requested her
not to communicate with the outgoing auditor. It was contended that
professional courtesy should not override statutory provisions and that she had
acted bona fide in accepting the audit assignment. The respondent also relied
upon email exchanges and contended that there was no deliberate violation of
ethical standards.
Court
Order / Findings
The
Board of Discipline examined the provisions of Item (8) of Part I of the First
Schedule to the Chartered Accountants Act, 1949 and the Code of Ethics, 2009,
and observed that two mandatory conditions are prescribed: prior communication
with the outgoing auditor and such communication must be in writing. The Board
noted that the respondent expressly admitted, both in written submissions and
during the course of hearing, that no written communication was made with the
complainant prior to acceptance of the statutory audit appointment.
The
Board further held that the obligation to communicate with the outgoing auditor
rests squarely on the incoming auditor and cannot be shifted to the auditee.
Allegations regarding mala fide intent of the outgoing auditor or instructions
of the company cannot justify non-compliance with ethical requirements. The
Board concluded that the respondent failed to adhere to the mandatory
safeguards prescribed under Item (8) of Part I of the First Schedule and was
therefore guilty of professional misconduct.
Important
Clarification
The
Board clarified that prior written communication with the outgoing auditor is a
substantive ethical requirement and not a mere formality. Incoming auditors
must independently evaluate objections or circumstances communicated by the
outgoing auditor, and failure to comply with this obligation constitutes
professional misconduct irrespective of the auditee’s instructions or disputes
over professional fees.
Final
Outcome
The
Board of Discipline held the respondent, CA Neha Bansal (M. No. 411989),
guilty of professional misconduct under Item (8) of Part I of the First
Schedule to the Chartered Accountants Act, 1949. A monetary penalty of
₹25,000 was imposed on the respondent.
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