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Part 2- SA 250


          QNO      Auditor's Responsibility (Compliance of Law)                           Old Course – (M23M)
          21.500   TITANIUM CNO-- SA250.120

                   While verifying the employee records in a company, it was found that a major portion of the labour

                   employed was child labour. On questioning the management, the auditor was told that it was outside his
                   scope of the financial audit to look into the compliance with other laws. Comment in accordance with
                   relevant Standards on Auditing.

          Answer  Compliance with Other Laws: As per SA 250, “Consideration of Laws and Regulations in an Audit of Financial
                   Statements”, the auditor shall obtain sufficient appropriate audit evidence regarding compliance with the

                   provisions of those laws and regulations generally recognised to have a direct effect on the determination
                   of material amounts and disclosures in the financial statements including tax and labour laws.

                   Further,  non-compliance  with  other  laws  and  regulations  may  result  in  fines,  litigation  or  other
                   consequences for the entity, the costs of which may need to be provided for in the financial statements, but
                   are not considered to have a direct effect on the financial statements.

                   In  the  instant  case,  major  portion  of  the  labour  employed  in  the  company  was  child  labour.  While
                   questioning by auditor, reply of the management that it was outside his scope of financial audit to look into
                   the compliance with other laws is not acceptable as it may have a material effect on financial statements.

                   Thus, auditor should ensure the disclosure of above fact and provision for the cost of fines, litigation or other
                   consequences for the entity. In case if the auditor concludes that non-compliance has a material effect on
                   the financial statements and has not been adequately reflected in the financial statements, the auditor shall
                   express a qualified or adverse opinion on the financial statement as per SA 705 “Modifications to the Opinion
                   in the Independent Auditor’s Report”.

          QNO      Indicators of Non-Compliance    Old Course - (M16E, SM17, N18R, M18E, N20E, SM21, N21M, M23M)
          22.000   TITANIUM CNO – Unique
                   R & M Co wants to be alert on the possibility of non-compliance with Laws and Regulations during the
                   course of audit of SRS Ltd R & M Co seeks your guidance for identifying the indications of non-compliance
                   with Laws and Regulations.
          Answer  Part I -- Relevant Standards & Laws
                       ▪  SA 250 “Consideration of Laws and Regulations in an Audit of Financial Statements”,
                   Part II -- Requirements of Relevant Standards & Laws
                    When the auditor becomes aware of the existence of, or information about, the following matters, it may
                   be an indication of non-compliance with laws and regulations:

                       ➢  Indicators of non-compliance (C2-PUPATE)
                          Payment  to  Country  other  than  source→Unusual  Cash  payment  →Unspecified
                          Payments  to  related  party  etc  →Unauthorised  transaction→Irrational  Purchase
                          price  →Agents  Fees  /  Commission  →Transactions  in  tax  haven→No  Exchange
                          documents
                              •  Payments for goods or services made other than to the Country from which the goods or
                                 services originated. (Non-Compliance of Customs Act)
                              •  Unusual Payments in Cash purchases in the form of cashiers’ cheques payable to bearer or
                                 transfers to numbered bank accounts. (May be bribe)
                              •  Payments for unspecified services or loans to consultants, related parties, employees or
                                 government employees. (Non-Compliance of Company Act)
                              •  Unauthorised transactions or improperly recorded transactions. (Secrets payments against
                                 law E.g. No approval as per company law etc.)
                              •  Purchasing at Prices significantly above or below market price. (Non-Compliance of Income
                                 Tax Act)


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