PRESENTATION ON REVISED SCHEDULE VI AT DEHRADUN BRANCH OF CIRC OF ICAI BY CA. Verendra Kalra, FCA,GRAD.CWA,DISA August 25, 2012 Dehradun Revised Schedule VI An Introduction Applicability As per notification [F. NO. 2/6/2008-C.L-V], dated 30-3-2011, the Schedule applies to all companies for the Financial Statements to be prepared for the financial year commencing on or after April 1, 2011. The schedule does not apply to: Insurance or banking company company engaged in the generation or supply of electricity (no format prescribed-hence may follow revised Schedule VI till such time a format is prescribed) any other class of company for which a form of Balance Sheet and Profit and Loss account has been specified in or under any other Act governing such class of company. CA Verendra Kalra Page 2 Revised Schedule VI Interim Financial Statements ( complete set) (as required by AS-25, Interim Financial reporting) to be prepared by companies as per revised Schedule VI.For presentation of Condensed interim Financial Statements, its format should conform to that used in the company’s most recent annual Financial Statements, i.e., the Old Schedule VI. However, if it presents a Complete set of Financial Statements, it should use the Revised Schedule VI. For balance sheet to be submitted to stock exchanges as prescribed under Clause 41 to the Listing Agreement of the Securities and Exchange Board of India For half yearly results: Clause 41 of the listing agreement prescribes separate format for presentation of half yearly results, Guidance note of ICAI mentioned that till the time a new format is prescribed by the Securities and Exchange Board of India (SEBI) under Clause 41, companies will have to continue to present their halfyearly Balance Sheets based on the format currently specified by the SEBI. However, SEBI vide its circular CIR/CFD/DIL/4/2012 dated 16th April 2012 have made changes in the format and therefore the companies should accordingly present their balance sheet in the new format. For Annual audited yearly results: Format of Revised Schedule VI should be used. CA Verendra Kalra Page 3 Revised Schedule VI Balance Sheet and Statement of Profit and Loss prescribed under the SEBI (Issue of Capital & Disclosure Requirements) Regulations 2009 (‘ICDR Regulations’) The formats of Balance Sheet and Statement of Profit and Loss under ICDR Regulations are “illustrative formats”. Accordingly, to make the data comparable and meaningful for users, companies should use the Revised Schedule VI format to present the restated financial information for inclusion in the offer document. Further also as per circular no. 62/2011 dated 5th September 20111, issued by Ministry of companies affairs, ‘the presentation of Financial Statements for the limited purpose of IPO/FPO during the financial year 2011-12 may be made in the format of the pre-revised Schedule VI under the Companies Act, 1956. However, for period beyond 31st March 2012, they would prepare only in the new format as prescribed by the present Schedule VI. Consolidated Financial Statements as per the requirements of AS-21 AS 21, Consolidated Financial Statements, requires that consolidated financial statements should be presented, to the extent possible, in the same format as adopted for the parent’s standalone financial statements and therefore Revised schedule VI to apply equally on consolidated financial statements of parent company. CA Verendra Kalra Page 4 Revised Schedule VI Highlights of Revised Schedule VI Revised Schedule VI has been framed as per the existing non-converged Indian Accounting Standards and has nothing to do with the converged Indian Accounting Standards. Revised schedule VI is not in convergence to IFRS. In fact, the changes made are more towards convergence with IAS 1. The Revised Schedule VI requires that if compliance with the requirements of the Act and / or the notified Accounting Standards requires a change in the treatment or disclosure in the Financial Statements as compared to that provided in the Revised Schedule VI, the requirements of the Act and / or the notified Accounting Standards will prevail over the Schedule. The Revised Schedule VI clarifies that the requirements mentioned therein for disclosure on the face of the Financial Statements or in the notes are minimum requirements. Line items, sub-line items and sub-totals can be presented as an addition or substitution on the face of the Financial Statements when such presentation is relevant for understanding of the company’s financial position and /or performance. CA Verendra Kalra Page 5 Revised Schedule VI Few instances are given below: Earnings before Interest, Tax, Depreciation and Amortization (EBITDA) is often an important measure of financial performance of the company. Hence, a company may choose to present the same as an additional line item on the face of the Statement of Profit and Loss. Users and stakeholders often want to know the liquidity position of the company. To highlight the same, a company may choose to present additional sub-totals of Current assets and Current liabilities on the face of the Balance Sheet. Rounding off rule amended as compared to old schedule VI. Turnover <Rs 100 crores: Nearest hundreds, thousands, lakhs or millions or decimals thereof. Turnover >Rs 100 crores: Nearest lakhs or millions or decimals thereof. Any Item of income or expenditure exceeding Rs 1 lakh or 1% from revenue from operations (earlier Rs 5000 or 1% of total revenue) will need to be separately disclosed in the notes to the statement of profit and loss . The Revised Schedule VI has eliminated the concept of ‘Schedules’ and such information is now to be furnished in the Notes to Accounts. CA Verendra Kalra Page 6 Revised Schedule VI The terms used in the Revised Schedule VI will carry the meaning as defined by the applicable Accounting Standards. There is an explicit requirement to use the same unit of measurement uniformly throughout the Financial Statements including notes to accounts, even for disclosing value of imports. Only vertical format of Balance Sheet prescribed. Statement of Profit and Loss does not mention any appropriation item on its face as against the old schedule VI. Below the line adjustments to be shown under ‘reserves and surplus’. Disclosure requirements of the revised schedule VI are in addition to and not in substitution to the notified Accounting Standards. For instance specific disclosure required by AS-24 Discontinuing Operations on the face of the Statement of Profit and Loss account which is not required by Revised Schedule VI. Disclosures required by the Acts will continue to be made in the Notes to Accounts. For instance: Separate disclosure required by Section 293A of the Act for donations made to political parties. Disclosures required under the Micro, Small and Medium Enterprises Development (MSMED) Act, 2006 Classification of assets and liabilities into current and non-current. CA Verendra Kalra Page 7 Revised Schedule VI Balance between too much aggregation and too much information should be maintained while making disclosures. Principles of aggregation in lAS1 are as under: Dissimilar items must be presented separately. If an individual item is not 'sufficiently material', it may be aggregated. What is not sufficiently material on the face of financial statements may be sufficiently material for the purpose of Notes. (Presentation on revised schedule VI by Pooja Gupta) A company needs to present comparative information for disclosures required under Revised Schedule VI even if their current period amount is Nil. (FAQ’s on revised schedule VI) For any clarification on issues, reference should be made to such material, which is official and recognized i.e Companies Act, Accounting Standards, Revised Schedule VI and ICAI publications. (FAQ’s on revised schedule VI) CA Verendra Kalra Page 8 Revised Schedule VI Disclosures dispensed off Information regarding licensed capacity, installed capacity and actual production Quantitative details of items purchased and consumed by manufacturing company Quantitative details of items by trading company Disclosure of brokerage and commission on sales including commission paid to selling agents Disclosure regarding managerial remuneration and computation of net profit for calculation of commission Information on investments purchased and sold during the year Disclosure of Investments, sundry debtors and loans & advances pertaining to companies under the same management Maximum amounts due on account of loans and advances from directors or officers of the company CA Verendra Kalra Page 9 Revised Schedule VI Classification into current and non current Current and Non Current asset “An asset shall be classified as current when it satisfies any of the following criteria: (a) it is expected to be realized in, or is intended for sale or consumption in, the company’s normal operating cycle; (b) it is held primarily for the purpose of being traded; (c) it is expected to be realized within twelve months after the reporting date; or (d) it is Cash or cash equivalent unless it is restricted from being exchanged or used to settle a liability for at least twelve months after the reporting date. All other assets shall be classified as non-current.” Current and Non Current liability “A liability shall be classified as current when it satisfies any of the following criteria: CA Verendra Kalra Page 10 Revised Schedule VI (a) it is expected to be settled in the company’s normal operating cycle; (b) it is held primarily for the purpose of being traded; (c) it is due to be settled within twelve months after the reporting date; or (d) the company does not have an unconditional right to defer settlement of the liability for at least twelve months after the reporting date. Terms of a liability that could, at the option of the counterparty, result in its settlement by the issue of equity instruments do not affect its classification. All other liabilities shall be classified as non-current. “An operating cycle is the time between the acquisition of assets for processing and their realization in cash or cash equivalents. Where the normal operating cycle cannot be identified, it is assumed to have a duration of twelve months.” Operating cycle refers to Gross operating cycle. Payment period of trade payables is not deducted.(#) Any specific inventory purchased, special production lot or special sale contract should not be taken into account while calculating the normal operating cycle of an enterprise. (#) CA Verendra Kalra Page 11 Revised Schedule VI Disclosure regarding operating cycle Though not specifically required, a company should disclose its operating cycle, especially if it is beyond 12 months. Operating cycles might be different for different class of enterprises and for separate lines of business. For example, in case of distillery, winer; wines in the process of maturing will be current assets even if it takes several years to mature. (*) Sample disclosures for a real estate industry published Oberoi Realty limited The Company’s normal operating cycle in respect of operations relating to under construction real estate projects may vary from project to project depending upon the size of the project, type of development, project complexities and related approvals. Operating Cycle for all completed projects and hospitality business is based on 12 months period. Assets & Liabilities have been classified into Current and Non Current based on Operating Cycle of respective businesses. CA Verendra Kalra Page 12 Revised Schedule VI Mahindra Life space developers limited Based on the nature of activity carried out by the company and the period between the procurement and realisation in cash and cash equivalents, the Company has ascertained its operating cycle as 5 years for the purpose of Current – Non Current classification of assets & liabilities. How to compute operating cycle (#) Carry out the item wise average inventory holding period. Find out weighted average inventory holding period Review credit policy with respect to different kinds of receivables (for this purpose advance from same customer is an offset against receivables) Find out weighted average collection period Lead-time for procuring raw material (time taken by the supplier from the order to delivery) should be included in the operating cycle. Example for calculation of operating cycle Given: Holding period of raw material 5 months CA Verendra Kalra Page 13 Revised Schedule VI Holding period of finished goods 4 months Production cycle ½ month Collection period of trade receivables 3 months Payment period of trade payables 3 months Calculation of operating cycle Gross operating cycle would be 12 ½ months (sum of all the above) –trade payables are not to be deducted. Practical Issues on Current and Non Current classification Inventories (#) How to determine inventories as current/non-current? Firstly, apply the operating cycle criteria using age analysis from the date of acquisition. Date of acquisition is as under: Particulars Date of acquisition CA Verendra Kalra Page 14 Revised Schedule VI Raw material inventories Date of purchase Work in progress Date of commencement of process Finished stock Date on which production completed Stock in trade Date of purchase Spares and consumables Date of purchase If the inventory holding period falls within the operating cycle, then the inventory is current. For inventory having holding period beyond op. cycle, go to the second test as mentioned here. Secondly, inventories which by age analysis are classified as non current are tested for consumption/realisability within 12 months after reporting date. If it is realized within 12 months, it is current. Otherwise, we go to the third stage test. Thirdly, assets held primarily for the purpose of being traded are to be classified as current assets. However, if the inventories are not sold within the normal operating cycle or after 12 months of reporting date, ‘held for trade status becomes doubtful’ Illustrations: Stock taking and age analysis carried out for a company reflects the following. CA Verendra Kalra Page 15 Revised Schedule VI S.No. Item Amount Age analysis Planned (Rs in upto reporting sales/ millions) date consumption (in months) 1.a Spares 1.b 2.a 39 100 Finished goods 2.b 2.c 100 100 1.02.13 15 200 Raw materials 2.d 200 100 1.07.12 1.11.12 1.07.13 9 1.05.12 1.03.12 Operating cycle of the company -6 months Reporting date-31.03.12 Analyse the same for current/non-current classification Solution: CA Verendra Kalra Page 16 Revised Schedule VI On the basis of first step for checking operating cycle criteria – all the above are non current On the basis of second step for checking the realisabilty/consumption within 12 months of operating cycleItems under 2.b i.e finished goods are not expected to be realized by 31.3.13 and hence classiy as non current On the basis of third step for checking the condition of primarily held for trading- Since the inventories are held for trading, they are classified as Current. Hence all the inventories are considered as current. Y ltd purchased raw material but the product line is temporarily discontinued because of legal dispute. Reporting date of the company is 31.3.12. The board estimates the expected date of consumption of raw material within 6 months i.e 30.06.2012. In case dispute not settled the raw materials will be sold to other manufacturer. Classification: Inventories should be classified as current on the reporting date. Basis for classification: Though the raw material are slow moving, the company expects to consume/realize the same till 30.06.12 which is within 12 months of the reporting date. CA Verendra Kalra Page 17 Revised Schedule VI Conclusion: Generally, the inventories of raw material, work in progress and finished goods are classified as ‘non current’ in very abnormal cases. But inventories of spares should be analysed for current and non current classification. Trade payables and Trade Receivables (#) How to classify trade receivable/payable as current/non current? They are classified as current if: they are expected to be settled within the companies operating cycle expected to be realized /due to be settled within 12 months after the reporting period. Date of acquisition is as under: Particulars Date of acquisition Trade receivables Date of sale Trade payables Date of purchase CA Verendra Kalra Page 18 Revised Schedule VI Illustrations: Trade payables Reporting date- 31.3.12 Trade payable expected to be settled -01.05.13 Operating cycle of company- 8 months Classification -Non Current Basis of classification-Not expected to be settled within operating cycle or upto 12 months from reporting date i.e 31.03.13. Trade Receivables Trade receivable recognized on 01.07.2010 Operating cycle- 12 months Reporting date- 31.03.2011 Contract date of realization-30.06.12 Classification- Non Current CA Verendra Kalra Page 19 Revised Schedule VI Basis for classification-Not expected to be settled within the company’s operating cycle i.e 30.06.11 and not expected to be realized within 12 months of reporting period i.e 31.03.12 Analysis of other assets/liabilities into current and non current (#) How to determine the classification into current/non-current? To check the expected realisability and settlement within 12 months after reporting date. The concept of operating cycle is not applied to assets and liabilities other than inventories, trade receivables and payables. Illustrations: Investments A ltd invested in equity shares of a company. It intends to sell the shares within 12 months of Reporting Date. Operating cycle of the company is 14 months. Classification: Current, since it is expected to be sold within 12 months from the reporting date. Operating cycle period irrelevant. CA Verendra Kalra Page 20 Revised Schedule VI A ltd invested in GOI bonds of Rs 500 lacs maturing on 30.09.10 and Rs 1000 lacs maturing on 30.06.11. The reporting date of the company is 31.03.10. The original maturities of the bonds was 10 yrs. Classification: Bonds worth Rs 500 lacs maturing on 30.09.10 would be considered as current. Bonds worth Rs 1000 lacs maturing on 30.06.11 would be considered as non-current. It is important to note here that the original maturity has nothing to do with the classification. It is only the remaining maturity that matters. An entity has acquired leasehold land which has original lease period of 30 yrs and remaining lease period as on reporting date is 6 months. Classification: Investment property is classified as ‘non current’ by nature and hence should not be reclassified into current unless classified as held for sale within 12 months. A company has its investment in preference shares, which are convertible into equity shares within one year from the balance sheet date. Classification: Since realization is not into cash and cash equivalents, it will be treated as non-current. Advances and deposits CA Verendra Kalra Page 21 Revised Schedule VI Mobilization advance given to contractor for revenue purpose. Classification: on the basis of estimated billing schedule, the portion of advance which is projected to be adjusted within 12 months after the reporting date is classified as current and balance is classified as non current. Loans and advances given to employees Classification: should be bifurcated into current and non-current portion considering the recovery within/after 12 months of the balance sheet date determined on the basis of planned recovery schedule of such advances. Security deposits Classification: Normally classified as non-current, unless there is evidence that a deposit shall be withdrawn within 12 months. Loans Entity enjoys the right for discretionary roll over of loan for at least a period of 12 months from the reporting date. CA Verendra Kalra Page 22 Revised Schedule VI Classification: Since the company has a discretionary right to roll over the period of loan, the same would be classified as non-current. Breach of loan clause resulting into loan repayable on demand on call from lender Classification: As per IFRS : If such breach takes place before the balance sheet date, loan should be classified as current. Such classification would not change even if the lender issues letter after the balance sheet date but before the authorization of accounts stating that the payment will not be demanded. Such a case only becomes the basis for disclosure of a non adjusting event as per IAS 10, Events after balance sheet date. As per ICAI guidance note on revised schedule VI: In case of minor breach in terms of contract the loan should not be treated as payable on demand and should therefore be considered as current/non-current on the basis of original payments terms. However, it may be noted that schedule VI does not cover these classification issues. An entity raised a loan from bank which it has rescheduled for pre-payment after the reporting date but before the authorization of accounts. CA Verendra Kalra Page 23 Revised Schedule VI Classification: As per IAS 1, the entity should classify the loan as current if it is due for settlement within 12 months from the reporting date even if as per the original terms the loan is payable after 12 months from the reporting date. Provisions Warranty provisions The entity should estimate the amount of expenses to be incurred within 12 months after reporting date and should classify the same as current. Provisions for employee benefits under defined benefit scheme Provisions which fall due within 12 months after the reporting date should be classified as current provisions. Segregation from actuary should be sought for such classification while obtaining actuarial report. Funded and unfunded post-employment benefit obligations CA Verendra Kalra Page 24 Revised Schedule VI Amount due for payment to the fund within 12 months created for this purpose is treated as current liability. For instance in case of contract with LIC, if the LIC demand is known, then that portion will be reflected as a current liability. If the actuarial valuation is higher, in that case the difference between the actuarial valuation and the LIC demand will be treated as a long term provision. (@) Regarding unfunded post-employment benefit obligations, amount of obligation attributable to employees who have already resigned or are expected to resign is a current liability. The remaining amount attributable to other employees is classified as non-current liability. If the management believes that the amount of current liability is not material, the entire amount may be classified as non-current Others Security deposit received The company has received security deposit from its customers / dealers. Either of the company or the customer / dealer can terminate the agreement by giving two months notice. The deposits are refundable within one month of termination. However, based on past experience, it is noted that deposits refunded in a year are not material, with 1% to 2% of the amount outstanding. CA Verendra Kalra Page 25 Revised Schedule VI Classification: As per Revised Schedule VI, a liability is classified as current if the company does not have an unconditional right to defer its settlement for at least 12 months after the reporting date. However, can be treated as non-current as based on past experience, only 2-3 % of deposits have been withdrawn in the past. Mat credit /service tax credit available To the extent MAT credit is expected to reverse within 12 months – It is current. Professional judgment is to be applied for service tax credit receivable CA Verendra Kalra Page 26 Revised Schedule VI Presentation, Classification and Disclosure requirements as per Revised Schedule VI- SIGNIFICANT ISSUES Part I. Balance Sheet I. EQUITY AND LIABILITIES 1. Shareholders’ fund (a) Share Capital Numbers of shares held by each shareholder holding more than 5% of shares on balance sheet date to be disclosed. Calls unpaid on shares are to be disclosed separately as per the Revised Schedule VI, as against shown as a deduction from called up capital in the case of old schedule VI. However, the unpaid amount towards shares subscribed by the subscribers of the Memorandum of Association should be considered as CA Verendra Kalra Page 27 Revised Schedule VI 'subscribed and paid-up capital' in the Balance Sheet and the debts due from the subscriber should be appropriately disclosed as an asset in the balance sheet. Calls unpaid by directors and officers of the company, needs to be disclosed as against only directors in old schedule VI. Disclosures regarding preference shares AS-30, 31 and 32 regarding financial instruments recognition and measurement, disclosures are yet to be notified and section 85 of the companies act describes preference shares as capital. Therefore, Preference Shares would be classified as Share Capital. Preference shares of which redemption is overdue should continue to be disclosed under the head ‘Share Capital’ Reconciliation of the number of shares outstanding at the beginning and at the end of the reporting period is to be disclosed separately for both Equity and Preference Shares and for each class of share capital within Equity and Preference Shares. The requirement of disclosing the source of bonus shares is omitted in the Revised Schedule VI. Proposed increase in share capital arising out of agreed conversion of debentures/bonds/loans need to be disclosed. CA Verendra Kalra Page 28 Revised Schedule VI (b) Reserves and Surplus Revised Schedule VI does not lays down requirement of “transferring capital profit on reissue of forfeited shares to capital reserve”, however since profit on re-issue of forfeited shares is basically profit of a capital nature and, hence, it should be credited to capital reserve. The terminology used under revised schedule VI for excess of issue price of shares over their face value is “Securities Premium Reserve” as against “Securities Premium Account” referred to in the act. The terminology of the Act should be used. The Revised Schedule VI requires Share Options outstanding account to be shown as a part of ‘Reserve and Surplus’ instead of a separate line item. It may be noted that the disclosure of share option outstanding under reserves and surplus would also impact the balance of reserves and surplus to be considered for compliance with various provisions of law. Thus the balance of ‘share options outstanding account’ would now be considered as part of the reserves to determine the applicability of Companies (Auditor’s Report) Order, 2003 (CARO). CA Verendra Kalra Page 29 Revised Schedule VI The reserves not specifically mentioned in the schedule are to be classified under ‘other reserves’. The amount of each reserve however, needs to be shown separately. For example reserves to be created under other statues like Tonnage tax reserve to be created under Income tax act. Money received against share warrants (c) ‘Share warrants’ are financial instruments which give the holder the right to acquire equity shares. Since shares are yet to be allotted these are not reflected as part of Share Capital but as a separate line-item – ‘Money received against share warrants.’ 2. Share application money pending allotment Share application money not exceeding the issued capital and to the extent not refundable is to be disclosed under this line item. The amount of share application money received over and above the issued capital or where minimum subscription requirement is not met should be shown under the head “Other Current Liabilities” Various disclosures such as terms and conditions, no. of shares, amount of premium, period etc need to be made in respect of amounts classified under both Equity as well as Current Liabilities, wherever applicable. CA Verendra Kalra Page 30 Revised Schedule VI Calls in advance is not part of the share capital and need to be reflected under ‘other current liabilities’. Share suspense account Sometimes company agrees to issue shares to the vendor against purchase of assets or in a scheme of amalgamation agrees to issue shares to discharge purchase consideration. If the assets have been purchased but the shares against the same have not been issued till the balance sheet date, the same should be reflected as ‘share suspense account’ as separate heading reflecting only the face value of such shares. The amount of premium should be reflected under ‘reserves and surplus’ as ‘share premium suspense account’. As per revised schedule VI ‘share suspense account and share premium suspense account’ should be classified under share application money pending allotment. The reason for the same being that consideration for the same has been received in kind but shares have not been issued. (#) 3. Non current liabilities (a) Long-term borrowings Long-term borrowings shall be classified as: (i) Bonds/debentures; CA Verendra Kalra Page 31 Revised Schedule VI (ii) Term loans; - from banks; -from other parties; (iii)Deferred payment liabilities; ($) Deferred payment liability would include any liability for which payment is to be made on deferred credit terms. Only those portions of deferred payment liabilities that are non-current shall be disclosed under longterm borrowing. Examples of deferred payment liabilities include: deferred sales tax liability deferred payment for acquisition of fixed assets (iv) Deposits; (v)Loans and advances from related parties; (vi)Long term maturities of finance lease obligations; (vii)Other loans and advances (specify nature). CA Verendra Kalra Page 32 Revised Schedule VI The phrase "long-term" and “term loan” has not been defined under Revised Schedule VI, definition of “non current liability” may be used as a synonymic for “long term liability”. Term loans would constitute a having a fixed or pre-determined maturity period or a repayment schedule. Long term borrowings to be classified as secured and unsecured and nature of security to be specified in each case. Disclosure of all defaults in repayment of loans and interest to be specified in each case. “Loan” relates to all items listed under the category of borrowings such as bonds/ debentures, deposits, deferred payment liabilities, finance lease obligations, etc. and not only to items classified as “loans” such as term loans, or loans and advances ,etc. Earlier no such disclosure was required in the financial statements and such defaults were to be reported under Companies auditors’ report order. The disclosures under CARO still continues. Disclosures as to period and amount of continuing default in case of long-term borrowing and default in case of short-term borrowing as on the Balance Sheet date is required. If the default has been made good after the balance sheet date but before the approval of the financial statements, it is advisable that this fact is mentioned CA Verendra Kalra Page 33 Revised Schedule VI Defaults pertaining to non compliance with debt covenants need not be reported. Current maturities of all long term borrowings will be disclosed under “other current liabilities”. Personal security given by promoters, other shareholders or any third party for any borrowing, would not constitute borrowing as secured. However, disclosure is required. (b) Deferred tax liabilities (Net) (c) Other Long term liabilities (d) Long-term provisions Provision for warranties to be included here. Employee benefits Leave encashment: o To the extent, the employee has unconditional right to avail the leave, the same needs to be classified as “current” even though the same is measured as ‘other long-term employee benefit’ as per AS-15. o In case of complexities as to the term of employee contract and leave policy, the amount of Noncurrent and Current portions of leave obligation should normally be determined by a qualified Actuary. CA Verendra Kalra Page 34 Revised Schedule VI 4. Current liabilities (a) Short-term borrowings Short-term borrowings will include all loans repayable within a period of 12 months from the date of the loan. In case of loans guaranteed by directors or others, disclosure required. Others will include non-related parties also. Current maturity of long-term borrowings should not be classified as short-term borrowing. They have to be classified under Other current liabilities. (b) Trade payables Amounts due under contractual obligations not to be included within Trade payables unlike the old schedule VI which included the same under ‘sundry creditors’. Contractual obligations include: dues payables in respect of statutory obligations like contribution to provident fund, purchase of fixed assets CA Verendra Kalra Page 35 Revised Schedule VI interest accrued on trade payables (c) Other current liabilities Current maturities of long term debts to be shown under this head. Trade Deposits and Security Deposits to be classified here. Statutory dues such as Withholding taxes, Service Tax, VAT, Excise Duty etc to be disclosed here. Unclaimed dividend is payable on demand and is therefore to be classified as current liability. Bonus payable within 12 months of balance sheet date Accumulated leaves outstanding Funded post benefit employee contributions to the extent of current portion Deferred revenue is to be disclosed under this head even if the related service is not expected to be performed within 12 months of the reporting date. Interest accrued and due on borrowings to be disclosed here Interest accrued but not due on borrowings to be disclosed here to the extent of current portion. Non current portion to be disclosed under other non current liabilities. CA Verendra Kalra Page 36 Revised Schedule VI (e) Short-term provisions Provision for dividend, Provision for taxation (unless it relates to disputed tax case not expected to be settled within 12 months). Provision for warranties, etc. would be disclosed here. Provision for proposed dividend needs to be disclosed only in the notes as per the revised schedule. However, to comply with the requirements of AS-4 and Events Occurring after the Balance Sheet date the same needs to be adjusted in the balance sheet. Hence, the same needs to be disclosed under provisions in the balance sheet in addition to the requirements of the notes. Contingent Liabilities The meaning of Contingent Liabilities has to be construed from AS-29 Provisions, contingent liabilities and contingent asset. Contingent liability would include: Claims against the company not acknowledged as debts. Guarantees CA Verendra Kalra Page 37 Revised Schedule VI When a company undertakes to perform its own obligations, and for this purpose issues a "guarantee", it does not represent a contingent liability. For instance performance guarantees and counter guarantees given by the company to its bankers does not constitute guarantee. Commitments The word ‘commitment’ has not been defined in the Revised Schedule VI. The Guidance Note on Terms Used in Financial Statements issued by ICAI defines ‘Capital Commitment’ as future liability for capital expenditure in respect of which contracts have been made. Hence, drawing inference from such definition commitment would imply future liability for contractual expenditure. ’ Commitments would include: Estimated amounts of contracts remaining to be executed. Uncalled liability on partly paid shares/other investments Amount of dividends proposed to be distributed to equity/preference shareholders Commitments for non-cancellable leases, are required by AS 19, Leases Employee contracts related to commitment ESOPS or pre mature termination compensation Purchase or sale commitments CA Verendra Kalra Page 38 Revised Schedule VI Commitments under construction contract by the contractor Commitment to fund subsidiaries, associates and joint ventures Commitments of inter corporate loans or guarantees The management should disclose “non cancellable contractual commitments (i.e cancellation of which would result in penalty disproportionate to the penalty involved)” which are material in understanding the financials of the company. To illustrate a few buy-back arrangements, commitments to fund subsidiaries and associates, non-disposal of investments in subsidiaries and undertakings, derivative related commitments, etc II.ASSETS (1) Non-current assets (a) Fixed assets (i) Tangible assets CA Verendra Kalra Page 39 Revised Schedule VI Office equipment has been introduced as a separate line item while dropping items like live stock, railway sidings, etc. However, if the said items exist, the same should be disclosed as a separate asset class. A reconciliation of the gross and net carrying amounts of each class of assets at the beginning and end of the reporting period showing additions, disposals, acquisitions through business combinations and other adjustments and the related depreciation and impairment losses/reversals shall be disclosed. Asset disposals through demergers may also be disclosed separately for each class of asset. Capitalization of exchange differences to be shown as ‘other adjustments’ separately for each class of asset. Reconciliation of opening and closing impairment also needs to be made like depreciation. Amounts written-off on reduction of capital or revaluation of assets or where sums have been added on revaluation of assets, every Balance Sheet subsequent to date of such write-off or addition shall show the reduced or increased figures. Disclosure specifying the amount and date should be given by way of note for the first 5 yrs subsequent after such reduction or increase. However, details required by AS 10 will have to be given as long as the asset is held by the company. CA Verendra Kalra Page 40 Revised Schedule VI Assets under lease are required to be separately specified under each class of asset. In the absence of any further clarification, the term“under lease” should be taken to mean assets given on operating lease in the case of lessor and assets held under finance lease in the case of lessee. Leasehold improvements should continue to be shown as a separate asset class. Assets belonging to discontinuing operation should be classified as current since they are expected to be realized within 12 months. (ii) Intangible assets Classification of intangible assets introduced. Revaluation of intangible assets is not permitted by AS 26. Other disclosures mentioned above for ‘Tangible assets’ are also applicable to ‘Intangible assets’. (iii) Capital work-in-progress Capital advances should be included under Long-term loans and advances and not under capital work-inprogress. (iv) Intangible assets under development CA Verendra Kalra Page 41 Revised Schedule VI (b) Non-current investments Definition of ‘current’ (and consequently non-current) investment as per the revised Schedule does not exactly correspond to AS 13, Accounting for Investments which defines ‘current investment’ as “an investment that is by its nature readily realizable and is intended to be held for not more than one year from the date on which such investment is made”. As per the definition of ‘current asset’ in the revised Schedule, the period of realization is “within 12 months after the reporting date”. Applying both AS 13 and requirements of revised Schedule VI: Generally, an investment that qualifies as a ‘current investment’ under AS 13 would also fall under the ‘current’ category under the revised schedule. Investments that qualify as ‘long-term investments’ under AS 13 may be bifurcated into ‘current’ and ‘noncurrent’ categories of the revised Schedule as follows: those which are expected to be realized within twelve months after the reporting date may be presented in the ‘current’ category as ‘current portion of long-term investments’ under relevant sub-heads. Other longterm investments may be presented under non current category. CA Verendra Kalra Page 42 Revised Schedule VI Partly paid investments to be separately disclosed. Investment carried at other than cost to be disclosed separately specifying the method of valuation. Part redemption of debenture held as investment to be bifurcated into current and non current. “Trade investments” has not been defined under Revised Schedule VI or in Accounting Standards. In general parlance, it would mean investment made by a company in shares or debentures of another company, to promote the trade or business of the first company. Diminution of value of investment The amount of provision for diminution (other than temporary diminution) in value netted-off for each long-term investment, should be disclosed separately. Further, the aggregate amount of provision made in respect of all noncurrent investments should also be separately disclosed to comply with the specific disclosure requirement in Revised Schedule VI. Till the time the term “Controlled special purpose entities” is defined by the revised schedule VI, accounting standard or the act, no separate disclosure under this head required. Nature and extent i.e number and face value of shares to be disclosed separately in each body corporate. Further disclosure as to fully paid or partly paid investments need to be disclosed. CA Verendra Kalra Page 43 Revised Schedule VI Investment in ‘Partnership firms’ requires disclosure as to the name of the partners, total capital and share of each partner in the profit. Such information to be given as at the companies balance sheet date. In case of difference in the date of balance sheet of firm and company necessary adjustments should be made to give effect to necessary transactions. In case of difference in reporting dates of more than 6 months separate disclosure required. Investments in partnership firms will not include investments in limited liability partnerships(LLPs) since as per LLP Act, LLP is a body corporate.Investment property required to be disclosed here. However IFRS requires its presentation as a separate line item. AS 13 Accounting for Investments, defines an investment property is an investment in land or buildings that are not intended to be occupied substantially for use by or in the operations of the investing enterprise. (c) Deferred tax assets (net) (d) Long-term loans and advances CA Verendra Kalra Page 44 Revised Schedule VI Capital advances are to be reflected here as against capital work in progress as per old schedule VI. Further, bifurcation of capital advances into current and non current not required irrespective of when the fixed asset is expected to be received. Allowance for bad and doubtful loans and advances shall be disclosed under the relevant heads separately. Disclosures for loans and advances to related parties beyond the requirements of AS-18 related party disclosures not required. Advance tax, CENVAT credit receivable, VAT credit receivable, Service tax credit receivable, etc. which are not expected to be realized within 12 months or operating cycle whichever is longer is to be disclosed here. (e)Other non-current assets Long term Trade Receivables to be disclosed under this head. Requirement of disclosure of trade receivable exceeding 6 months from the date they become due for payment is not required in case of non current portion of trade receivables. (2) Current assets CA Verendra Kalra Page 45 Revised Schedule VI (a) Current investments The disclosure requirements mentioned above to ‘non-current investments’ to the extent applicable, will also apply to ‘current investments’. No requirement to classify investments into trade & non-trade in respect of current investments. (b) Inventories (c) Trade receivables Term sundry debtors has been replaced with “trade receivables”. Trade receivables’ are defined as dues arising only from goods sold or services rendered in the normal course of business. Hence, amounts due on account of other contractual obligations can no longer be included in the trade receivables. Separate disclosure of trade receivables (only current portion) outstanding for a period exceeding six months from the date the bill/invoice is due for payment as against the date the bill/invoice is raised. Determining of due date for payment Companies having large number of customers need to define credit terms for all customers CA Verendra Kalra Page 46 Revised Schedule VI In absence of due date specifically agreed upon, normal credit period allowed by the company should be considered, depending upon the nature of goods and services sold and type of customers In cases where due date for payment is not agreed upon, normal credit period allowed by the company would be taken for computing the due date depending upon nature of goods sold and type of customers. (d) Cash and cash equivalents AS-3 cash flow statement, states that deposits with maturity of three months or less from the date of acquisition is considered as cash equivalent. Therefore, deposits with original maturity of less than 3 months would form part of cash equivalents. To comply with the requirements of Accounting Standard-3 on cash flow statements and to resolve the conflict with revised schedule VI, the caption “cash and cash equivalent” would be changed to “cash and bank balances” which may have two sub headings namely “cash and cash equivalent” and “other bank balances”. The former would include cash and cash equivalent in accordance with AS-3 and the remaining items would be covered under ‘other bank balances’. Accordingly only deposits with original maturity of three months or less only should be classified as cash equivalents. CA Verendra Kalra Page 47 Revised Schedule VI Bank deposits with original maturity of more than 12 months needs to be disclosed separately. This presentation is due to the following reasons: Earmarked bank balances example for unpaid dividend to be disclosed separately. Repatriation restrictions in respect of cash and bank balances shall be separately stated here. (c) Short-term loans and advances Allowance for bad and doubtful loans and advances shall be disclosed under the relevant heads separately. (d) Other current assets This is an all inclusive heading, which incorporates items which does not classify under any other asset category. Unbilled Revenue, unamortized premium on forward contracts etc to be included under this head. Miscellaneous expenditure class of asset has been deleted from revised Schedule VI Revised Schedule VI does not mention any disclosure for the unamortized portion of expense items such as share issue expenses, ancillary borrowing costs and discount or premium relating to borrowings. CA Verendra Kalra Page 48 Revised Schedule VI Therefore, they would be disclosed under the head “other current/ non-current assets”, depending on whether the amount will be amortized in the next 12 months or thereafter. Part II. Statement of Profit and Loss I. Revenue from operations “Revenue includes only the gross inflows of economic benefits received/receivable by the entity. Amounts collected on behalf of third parties is such as sales tax, value added tax etc are not economic benefits which flow to the entity and should be excluded from revenue” Revenue from operations in case of company other than finance company shall include: a. Sale of products b. Sale of services c. Other operating revenue CA Verendra Kalra Page 49 Revised Schedule VI To comply with the disclosure requirements of AS-9 Revenue recognition, excise duty has to be disclosed on the face of Statement of Profit and Loss. In doing so, a company may choose to present the elements of revenue from sale of products, sale of services and other operating revenues also on the face of the Statement of Profit and Loss instead of the notes. Other Operating revenue is revenue arising from the principal or ancillary revenue-generating activities, but which is not revenue arising from the sale of products or rendering of services. For instance sale of manufacturing scrap arising from operations for a manufacturing company. Revenue from operations in case of finance company shall include revenue from: a. Interest b. Other financial services The term finance company has would be construed to include companies carrying business of ‘Non banking financial institution’ as defined under the Reserve bank of India act. II. Other Income Other Income shall be classified as : (a)Interest Income CA Verendra Kalra Page 50 Revised Schedule VI (b) Dividend Income (c) Net gain/(loss) from investment Losses and gains are netted off, however if resulting is a loss the same should be disclosed under other expenses. (d) Other non operating Income The aggregate of other Income to be disclosed on the face of the Profit and loss account. Net foreign exchange gain should be classified as other income. As per old Schedule VI, parent company was to recognize dividends declared by subsidiary companies even after the date of the Balance Sheet if they were pertaining to the period ending on or before the Balance Sheet date. As per revised schedule VI, dividends should be recognized as income only when the right to receive dividends is established as on the Balance Sheet date. Further, necessary disclosures as per AS-5 should be given in the notes to accounts of the subsidiary company. As required by AS 13 “Accounting for Investments”, other income items such as interest income, dividend income and net gain on sale of investments should be disclosed separately for Current as well as Long-term Investments. CA Verendra Kalra Page 51 Revised Schedule VI I. Expenses (a) Cost of materials consumed If the company classifies packing material as raw material, its consumption will be shown here. Further, it would be better to show the description as “raw material including packing material” in this case. Internally manufactured Intermediates and components are to be excluded. They are to be disclosed as under: Such components if sold without further processing should be classified as ‘finished products’ and if further processed should be classified as ‘manufactured components’. In case of hybrid, the same should be classified as manufactured components’. The consumption of raw material should be on actual basis rather than on derived figure (i.e deducting the closing inventory from the total of the opening inventory and purchases) as this would conceal the figures of losses and wastage. Where the actual figure could not be determined, it is on the circumstances of the case to mention that the consumption is on derived figures. CA Verendra Kalra Page 52 Revised Schedule VI Shortages, losses and wastage which are within the norms and margins established by the company, should be included in the consumption. On the other hands shortages beyond the margins should not be included here. Stores, fuel, spare parts etc, which do not enter physically into the composition of the finished product, would not constitute “raw materials. Internal transfers from one department to another should be disregarded in determining the consumption figures to be disclosed. Break-up in terms of quantitative disclosures for significant items of Statement of Profit and Loss, such as raw material consumption, stocks, purchases and sales have been simplified and replaced with the disclosure of “broad heads” only. The broad heads need to be decided based on considerations of materiality and presentation of true and fair view of the Financial Statements. Broad head would be determined as per the nature and circumstances of the business. Ordinarily broad heads would constitute items covering 10% of total sale/services value. (b) Purchases of Stock-in-Trade (c) Changes in inventories of finished goods work-in progress and Stock-in-Trade CA Verendra Kalra Page 53 Revised Schedule VI (d) Employee benefits expense Where a separate fund is maintained for Gratuity payouts, contribution to Gratuity fund should be disclosed under the sub-head Contribution to provident and other funds. Salaries of persons engaged under a contract of service should be included and those engaged under a contract for services should not be reflected here. Contribution to funds to be disclosed under the head “contribution to provident and other funds”. Penalties and other similar amounts paid to the statutory authorities not to be disclosed here. They are to be disclosed under ‘other expenses’. (e) Finance costs Finance cost to be bifurcated into (i) Interest cost Finance charges on finance lease to be included under interest cost. Interest on shortfall in payment of advance tax should be classified under finance cost. Penalties under income tax act which are compensatory in nature should be treated as interest cost. CA Verendra Kalra Page 54 Revised Schedule VI Net exchange gain/loss on foreign currency borrowings to the extent considered as an adjustment to interest cost needs to be disclosed separately as finance cost (ii)Borrowing cost Amortization of issue expenses and discounts as per AS-16 are to be included here. Commitment charges, loan processing charges, guarantee charges, loan facilitation charges, discounts/premium on borrowings, other ancillary costs incurred in connection with borrowings, or amortization of such costs to be included under ‘Borrowing costs”. (iii) Net gain/loss on foreign currency transactions (f) Depreciation and amortization expense (g) Other expenses Wealth tax paid is not tax on income and should be included in Rates and taxes under other expenses. (h) Exceptional Items CA Verendra Kalra Page 55 Revised Schedule VI As per AS-5, “Net Profit or Loss for the period, Prior period items and changes in Accounting Policies” Exceptional items are items of income and expense within profit or loss from ordinary activities are of such size, nature or incidence that their disclosure is relevant to explain the performance of the enterprise for the period. Few instances of the same are: Written down of inventories to net realizable value Disposal of items of fixed assets Disposal of long term investments Litigation settlement Other reversals of provisions (i) Extraordinary Items Extraordinary items’ are items of income or expenses that arise from events or transactions that are clearly distinct from the ordinary activities of the enterprise and, therefore, are not expected to recur frequently or regularly. CA Verendra Kalra Page 56 Revised Schedule VI Few instances of the same are: Earthquake Profit/loss arising on disposal of brand Reversal of provision against advance and diminution in value of investment in a subsidiary consequent to amalgamation. (j) Prior period items (net) Revised schedule VI does not require separate disclosure of prior period items on the face of the profit and loss account. However, to comply with the requirements of AS-5, the same should be disclosed on the face of the profit and loss account. (k) Tax Expense Excess/Short provision of tax relating to earlier years should be separately disclosed. CA Verendra Kalra Page 57 Revised Schedule VI Other disclosures Value of imports calculated on C.I.F. basis by the company needs to be disclosed in respect of : (a)Raw materials; (b) Components and spare parts; (c) Capital goods. Disclosure is required in respect of imported capital goods in the statement of profit and loss account. It is undoubtedly anomalous to disclose the value of imports of capital goods by way of a note on the Statement of Profit and Loss, since by the very definition, capital assets do not form part of the Statement of Profit and Loss. However, since this is a specific requirement of revised schedule VI, the same has to be met with.Disclosure under this requirement relates to the imports as such. It is not linked with the consumption of the material or utilization of capital goods. The value of imports of raw materials, components and spare parts and capital goods is to be disclosed irrespective of whether or not such imports have resulted in an expenditure in foreign currency. CA Verendra Kalra Page 58 Revised Schedule VI If for any reason, there is some practical difficulty in disclosing the value of the imports on C.I.F. basis, a footnote should be appended to the statement indicating the precise method by which the value of imports has been arrived at. For example, it may be stated that, because of practical difficulties in disclosing the value of imports on C.I.F. basis, such disclosure has been made on F.O.B. basis. If the values directly available from its records would be those relating to F.O.B. terms, then In such cases, a standard formula may be applied in order to convert the F.O.B. values to C.I.F. For example, the company’s accountant may calculate that a loading of, say, eleven per cent on the F.O.B. values is ordinarily adequate and correct in order to convert the F.O.B. values to C.I.F. If a company purchases import entitlements and thereafter imports materials on the basis of those entitlements, the value of such imports would need to be disclosed. Value of imports should include goods which are in transit on the balance sheet date provided risk and rewards of ownership has passed to the purchasing company. Expenditure in foreign currency during the year Expenditure incurred in foreign currency on account of royalty, know-how, professional and consultation fees, interest and other matters needs to be disclosed. CA Verendra Kalra Page 59 Revised Schedule VI Amount to be disclosed on the basis of expense booked and not on the basis of remittance. It would be disclosed in Indian Rupee In cases where taxes at source have been deducted while making payments, it is preferable to disclose the gross amount of payment. Total value of all imported raw materials, spare parts and components consumed during the financial year and the total value of all indigenous raw materials, spare parts and components similarly consumed and the percentage of each to the total consumption need to be separately disclosed. Spare parts would not include stores. This disclosure is in addition to the disclosure pursuant to import of raw material etc, mentioned above. Imports should be construed as direct imports as well as indirect imports (i.e imports made by an independent principal) made to the company’s knowledge. Classification of imported and indigenous components is to be restricted to purchased components only ignoring any components manufactured internally. Total amount remitted during the year in foreign currencies on account of dividends needs to be disclosed. CA Verendra Kalra Page 60 Revised Schedule VI Total number of nonresident shareholders, the total number of shares held by them on which the dividends were due and the year to which the dividends relates needs to be separately disclosed. If dividend is paid to non resident in Indian rupee disclosure not required. Information is to be furnished in the year of actual payment of dividend i.e on cash basis rather than accrual basis. In case no dividend in foreign currency is remitted during the year, no need to disclose information in respect of non resident shareholders. Earning in foreign exchange need to be disclosed bifurcated into: (a) export of goods calculated on F.O.B. basis; (b) royalty, know-how, professional and consultation fees; (c) interest and dividends; and (d) other income (indicating the nature thereof). Disclosure to be made on accrual basis. In case of earnings received net off tax, the gross amount needs to be disclosed. CA Verendra Kalra Page 61 Revised Schedule VI Synchronization of Cash flow with revised schedule VI format AS 3 Cash Flow Statements does not mandate such presentation. Nor is such presentation required in Revised Schedule VI or Guidance Note on the Revised Schedule VI. Hence, it is not mandatory for a company to present separate movement / inflows and outflows from current and noncurrent components of various line items separately. CA Verendra Kalra Page 62 Revised Schedule VI Implementation challenges Number of implementation challenges would be faced by companies in the first year of application of the revised Schedule. While some of these challenges are general in nature, there would be many specific issues faced by companies from different sectors with completely diverse operating environments in bringing the presentation of their financial information in the revised universal format. Increased onus is also placed on management’s judgement in determining the presentation of assets and liabilities. To name a few the under mentioned areas would require concern of the management Significant conceptual changes specially with respect to classification of assets and liabilities into ‘current’ and ‘non-current’ and ‘operating cycle’ of a company. Breach of loan covenants. Contingent liabilities and commitments Ratio analysis and its impact on financial position of company CA Verendra Kalra Page 63 Revised Schedule VI Documentation and collection of evidence to support classification Interpretation vis a vis varying requirements in AS, Ind AS, IFRS, CARO and other laws CA Verendra Kalra Page 64 Revised Schedule VI Note: The source of information wherever so used for making this presentation has been mentioned in brackets at the relevant sections. In cases where not specifically mentioned , the same should be understood to be taken from the Guidance note on Revised Schedule VI issue by the Institute of chartered accountants of India. Other credits are from as under: *Presentation on revised schedule VI by Pooja Gupta @ FAQ’s issued by ICAI # Illustrated guide to revised schedule VI by Dr T.P Ghosh ($) Accounting and audit update by KPMG on Revised Schedule VI CA Verendra Kalra Page 65 Revised Schedule VI Thank you for your participation.Your queries or suggestions for improvement are always welcome and can be submitted via e-mail to verendra.kalra@nangia.com CA Verendra Kalra Page 66