Friday, 7 April 2017

Additional Disclosure requirements for Companies (including Section 8 Companies) Post Demonetization!



The Ministry of Corporate Affairs (MCA) has notified certain amendments in Schedule III to the Companies Act 2013, applicable with effect from 30th March 2017, requiring companies (this includes non-profit Section 8 Companies) to disclose the details of “Specified Bank Notes” (SBN) held and transacted during the period 8th November 2016 to 30th December 2016 (i.e. during the period when currency notes of Rs. 500/- and Rs. 1,000/- were demonetized or rendered as not legal tender).
 
Every company (including Section 8 Company) shall disclose the details of “Specified Bank Notes” (SBN) held and transacted during the period from 8th November 2016 to 30th December 2016. Consequently, the financial statement of all Companies for the financial year ended 31.03.2017 must compulsorily provide information as provided in the table below:


Specified Bank Notes (Rs. 500 & Rs. 1,000)
Other Denomination Notes
Total
Closing cash in hand as on 08.11.2016



(+) Permitted receipts



(-) Permitted payments



(-) Amount deposited in Banks



Closing cash in hand as on 30.12.2016




Further, as per MCA Notification No. G.S.R. 307(E) dated 30th March, 2017; there is an amendment in Companies (Audit and Auditors) Rules, 2014.  
In Rule 11 after clause (c), the following clause has been inserted, namely: “(d) whether the company had provided requisite disclosures in its financial statements as to holdings as well as dealings in Specified Bank Notes during the period from 8th November, 2016 to 30th December, 2016 and if so, whether these are in accordance with the books of accounts maintained by the company.”.

Rule 11 relates to matter to be included in ‘Auditor Report’ and as such, it will be binding for the auditors to bring up this information relating to Specified Bank Notes in its reports.


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