Facts of the
Case
A complaint was filed by CA Kamal Kumar Garg
against CA Rupesh Nagpal alleging professional misconduct in relation to
acceptance of tax audit assignments of M/s Mega Enterprises and M/s
Radica Enterprises for the Financial Year 2012–13.
The complainant was the tax auditor of the said
entities for the earlier year. It was alleged that the Respondent accepted the
tax audit assignments for the subsequent year without first communicating in
writing with the complainant, who was the existing auditor, as mandated under
the Chartered Accountants Act, 1949 and the Code of Ethics.
The Respondent accepted the tax audit and issued
audit reports without obtaining prior written communication or no-objection
from the complainant.
Issues
Involved
Whether the Respondent accepted tax audit
assignments previously held by another Chartered Accountant without first
communicating with him in writing, and whether such conduct constituted
professional misconduct under Item (8) of Part I of the First Schedule
to the Chartered Accountants Act, 1949.
Petitioner’s
Arguments
The complainant contended that he was the
continuing auditor for the relevant entities and that the Respondent violated
mandatory ethical requirements by accepting the tax audit without any prior
written communication. It was argued that such conduct undermines professional
discipline and violates the standards prescribed by the Institute.
The complainant further submitted that prior
communication is compulsory irrespective of any understanding between auditors
or clients.
Respondent’s
Arguments
The Respondent admitted that he did not communicate
with the complainant before accepting the tax audit assignments. He submitted
that the lapse occurred in good faith and without malafide intention.
The Respondent contended that the complainant had
conducted the audit for the earlier year at the request of the incoming auditor
and that the complainant was unable to take up the professional assignment for
subsequent years. He accepted that failure to communicate was his mistake and
assured that he would be careful in future.
Court Order
/ Findings
The ICAI Board of Discipline examined the
complaint, written submissions of both parties, and the relevant provisions of
the Chartered Accountants Act, 1949. The Board noted that the Respondent categorically
admitted that he did not communicate with the complainant prior to
accepting the tax audit of M/s Mega Enterprises and M/s Radica Enterprises for
Financial Year 2012–13.
The Board referred to Item (8) of Part I of the
First Schedule, which clearly mandates prior written communication with the
existing auditor before acceptance of an audit assignment. The Board held that
non-compliance with this requirement constitutes professional misconduct,
irrespective of intent or subsequent explanations.
Accordingly, the Board concluded that the Respondent
was guilty of professional misconduct.
Important
Clarification
The Board clarified that prior written
communication with the existing auditor is a mandatory professional obligation,
and any acceptance of audit without such communication constitutes professional
misconduct, even if done in good faith or due to oversight.
Final
Outcome
The ICAI Board of Discipline held CA Rupesh
Nagpal (M. No. 093500) Guilty of Professional Misconduct under Item (8)
of Part I of the First Schedule to the Chartered Accountants Act, 1949 read
with Section 21A(3).
By order dated 10 January 2022, the Board Reprimanded
the Respondent.
Disclaimer
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