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CA Ravi Taori
                   Responsibility With Respect to Internal Financial Controls               New Course – (M24E)
         QNO--
                   in Listed Companies (Big Companies)
         ICS.33.600
                   Bhaskar CNO – SA315-P2.380
                   Mr. Z, at the time of appointment as an independent director in EF Ltd. A listed company, came to know
                   that the Companies Act, 2013 has placed a greater emphasis on the effective implementation and reporting
                   on internal controls for a listed Company. He wants to know the responsibilities as casted under Companies
                   Act, 2013 with regards to Internal Financial Control for (1) Directors (2) Independent directors and (3) Audit
                   committee as per section 134(5)(e), 149(8) & 177(4) (vii) respectively of the Companies Act, 2013.
         Answer    Internal  financial  controls as  per  regulatory  requirements:  The  Companies Act 2013  has  placed  greater
                   emphasis on the effective implementation & reporting on the internal controls for a company. The term
                   “internal financial controls” is used at some places in Companies Act, 2013 casting responsibilities as under: -
                         Relevant provision of Companies Act,2013             Nature of Responsibility
                      Section 134(5)(e)                            In  case  of  listed  Companies,  the  Directors’
                                                                   responsibility  statement  shall  state  that  the
                                                                   Directors had laid down Internal financial controls
                                                                   to  be  followed  by  the  company  and  that  such
                                                                   Internal financial controls are adequate and were
                                                                   operating effectively.
                      As per Section 149(8) of the Act             The  company  and  independent  directors  shall
                                                                   abide  by  the  provisions  specified  in  Schedule  IV
                                                                   which  lays  down  the  Code  for  independent
                                                                   Directors. As per this code, the role and functions
                                                                   of  independent  directors  include  that  they  shall
                                                                   satisfy  themselves  on  the  integrity  of  financial
                                                                   information  and  that  financial  controls  and  the
                                                                   systems  of  risk  management  are  robust  and
                                                                   defensible.
                      Section 177(4)(vii) of the Act               Every audit Committee shall act in accordance with
                                                                   the terms of reference specified in writing by the
                                                                   Board which shall, inter alia, include - evaluation of
                                                                   internal  financial  controls  and  risk  management
                                                                   systems.



          QNO       IFC Vs IFCR                                   Old Course -- (N21R/N20E)
           ICS.34   Bhaskar CNO- SA315-P2.380
                    Explain  clearly  the  difference  between  Internal  Financial  Control  and  Internal  Controls  over  financial

                    reporting.
          Answer    Internal  Financial  Control  as  per  Section  134(5)(e),  “the  policies  and  procedures  adopted  by  the
                    company  for  ensuring  the  orderly  and  efficient  conduct  of  its  business,  including  adherence  to
                    company’s policies, the safeguarding of its assets, the prevention and detection of frauds and errors,
                    the  accuracy  and completeness  of  the  accounting  records,  and the  timely  preparation  of  reliable
                    financial information.”
                     On the other hand, Internal controls over financial reporting-is required where auditors are required
                    to express an opinion on the effectiveness of an entity’s internal controls over financial reporting, such
                    opinion  is  in  addition  to  and  distinct  from the  opinion  expressed  by  the  auditor  on  the  financial
                    statements.

          QNO     Weakness in ICS (Case Study) #Unique                         Old Course -- (P16M/N18R/M19M)
          ICS.39                                         New Course – Relevant, Concept Covered in New Course SM
                  In  a  medium  size  trading  organisation  the  accountant  was  given  additional  responsibility  of  making
                  recoveries  from  the  trade  receivables.  On  one  occasion,  when  an  insurance  claim  of  Rs  45,000  was
                  received, he credited the same to the account of a trade receivable and misappropriated the cash which


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