Facts of the Case
A complaint was filed by Shri Dharmendra Nagawat,
Jaipur, against CA Praveen Kumar Singhvi alleging professional misconduct
arising out of financial transactions connected with construction and allotment
of a residential flat at Alaknanda Apartments, Jaipur. The Respondent was
closely associated with M/s S.S. Builders, a concern run by his wife, and
actively participated in transactions involving the complainant and his family
members.
The complainant alleged that substantial amounts were
paid to M/s S.S. Builders and to the Respondent’s wife for construction of a
residential house and allotment of a flat, and that the Respondent, while
acting as a Chartered Accountant, witnessed agreements, facilitated
transactions, and received payments described as consultancy fees without
rendering any professional consultancy services. It was alleged that the
Respondent failed to maintain professional independence and integrity and
colluded in financial dealings detrimental to the complainant.
Issues Involved
Whether the Respondent failed to maintain independence
and integrity by acting in transactions involving close relatives, whether he
facilitated and witnessed financial transactions without adequate documentation
or professional justification, and whether such conduct amounted to “Other
Misconduct” under Item (2) of Part IV of the First Schedule to the Chartered
Accountants Act, 1949.
Petitioner’s Arguments
The complainant contended that the Respondent abused
his professional position by actively participating in transactions involving
his wife’s proprietary concern, receiving payments under the guise of
consultancy without evidence of services rendered, and facilitating financial
arrangements that caused loss and hardship to the complainant. It was argued
that such conduct demonstrated collusion, conflict of interest, and lack of
professional independence.
Respondent’s Arguments
The Respondent denied the allegations and submitted
that the amounts received were towards consultancy services rendered by M/s
S.S. Builders and not by him personally. He contended that he merely witnessed
certain transactions and did not directly receive amounts from the complainant.
The Respondent further argued that the disputes were civil in nature and that
criminal and police investigations were pending, and therefore disciplinary
proceedings should not be concluded.
Court / Authority Order and Findings
The Board of Discipline carefully examined the
documentary evidence, affidavits, bank statements, agreements, and statements
recorded under Section 161 of the Code of Criminal Procedure. The Board noted
that substantial amounts were transferred to M/s S.S. Builders and that the
Respondent’s wife admitted that amounts were shown as consultancy fees without
any real consultancy being provided.
The Board observed that the Respondent actively
participated in transactions, witnessed payments, and failed to maintain
professional distance despite clear conflict of interest arising from his close
relationship with the builder entity. The Board held that a Chartered
Accountant is expected to act with utmost integrity, independence and
objectivity, and the Respondent’s conduct fell far short of these standards.
The Board further held that disciplinary proceedings
are governed by the standard of preponderance of probabilities and need not
await the outcome of criminal proceedings. On evaluation of the material on
record, the Board concluded that the Respondent was guilty of “Other
Misconduct” within the meaning of Item (2) of Part IV of the First Schedule
read with Section 22 of the Chartered Accountants Act, 1949.
Important Clarification
The Board clarified that Chartered Accountants must
scrupulously avoid conflicts of interest and must not associate themselves,
directly or indirectly, in financial transactions involving close relatives
where professional independence is compromised. Receipt or facilitation of
payments without demonstrable professional services constitutes serious
professional misconduct.
Final Outcome
The ICAI Board of Discipline held CA Praveen Kumar
Singhvi (M. No. 070604) guilty of “Other Misconduct” under Item (2) of
Part IV of the First Schedule to the Chartered Accountants Act, 1949. In
exercise of powers under Section 21A(3) of the Act, by order dated 19
April 2023, the Board directed removal of the name of the Respondent
from the Register of Members for a period of 5 (five) years and imposed
a monetary penalty of ₹50,000 (Rupees Fifty Thousand only).
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