DEPRECIATION UNDER SCHEDULE II TO THE COMPANIES ACT, 2013- BY CA MOHIT BHUTERIA The recent enactment of the Companies Act, 2013 is a dawn of a new era. After bringing far-reaching changes in various areas, the spectrum of financial reporting has widened and brings higher responsibilities to those associated with financial reporting, be it the auditors or the management. One such area is Depreciation. THE 2013 ACT VS THE 1956 ACT, AN OVERVIEW: The Depreciation on fixed asset as per Schedule-II of Companies Act, 2013 became operational from 01/04/2014 vide MCA notification no S.O.902(E) dated 26/03/2014. From the date this Schedule comes into effect, the carrying amount of the asset as on that date— (a) shall be depreciated over the remaining useful life of the asset as per this Schedule; (b) after retaining the residual value, may be recognised in the opening balance of retained earnings where the remaining useful life of an asset is nil. Thus in respect of assets, whose remaining useful life is NIL, there is an option to charge the carrying amount of asset either to retained earnings or to the Statement of Profit and Loss. The table below highlights the key differences: Particulars Schedule II to the 2013 Act Schedule XIV to the 1956 Act Definition of the term Para 1 of Part A to Schedule Not Defined “depreciation”, II of the Companies Act, “depreciable amount” 2013 defines: and “useful life” “depreciation” as a systematic allocation of the depreciable amount of an asset over its useful life; “depreciable amount” of an asset is the cost of an asset or other amount substituted for cost, less its residual value. “useful life” of an asset is the period over which an asset is expected to be available for use by an entity, or the number of production or similar units expected to be obtained from the asset by the entity. Mode of Depreciation Useful Life Schedule II regime lays i.e As per life of the assets down (AS 6) or rates prescribed useful life to compute by Schedule XIV. depreciation. Shift Based Useful depreciation lives have been determined on the basis of single shift. For specified assets working on double shift, depreciation will increase by 50% and in case of triple shift by 100% proportionately for number of days used as such. Asset costing less No such Concept 100% Depreciation except than Rs. 5000 Depreciation revalued assets in certain cases on Entire charge to Incremental depreciation Statement of Profit and on revalued portion can Loss. be adjusted revaluation against reserve by transfer of an equivalent amount to the Statement of Profit and Loss based on the Guidance Note of the Institute of Chartered Accountants of India. Residual life Residual life not to be more No such concept. than 5 % of original cost with exceptions Component Schedule II introduced a No such concept. Approach new concept to estimate useful life of each component in an asset and depreciate that component specific over its estimated useful life. DEPRECIATION FOR INTANGIBLE ASSETS: No separate depreciation rate is prescribed for intangible assets. Rather, for the time being the same will be governed by notified Accounting Standards. Thus, guidance from AS-26, “Intangible Assets” needs to be taken to deal with amortization of intangible assets. However, in case of intangible assets (Toll Roads) created under ‘Build, Operate and Transfer’, ‘Build, Own, Operate and Transfer’or any other form of public private partnership route in case of road projects, amortisation in such cases may be done as follows:(a) Mode of amortisation Amortisation Rate = Amortisation Amount * 100 Cost of Intangible Assets (A) Amortisation Amount = Actual Revenue for the year (B) Projected Revenue from Intangible Asset (till the end of the concession period) (C) (b) Meaning of particulars are as follows = Cost of Intangible Assets (A) = Cost incurred by the company in accordance with the accounting standards. Actual Revenue for the year (B) = Actual revenue (Toll Charges) received during the accounting year. Projected Revenue from Intangible Asset (C) = Total projected revenue from the Intangible Assets as provided to the project lender at the time of financial closure / agreement. USEFUL LIFE The useful life of an asset shall not ordinarily be different from the useful life specified in Part C of Schedule II of Companies Act, 2013 and the residual value of an asset shall not be more than five per cent. of the original cost of the asset. However, where a company adopts a useful life different from what is specified in the said Schedule or uses a residual value different from the limit specified therein, the financial statements shall disclose the same and provide justification in this behalf duly supported by technical advice. For an entity using straight line method of depreciation as per Schedule II under the new Act, useful life has been reduced as compared to Schedule XIV under the 1956 Act. A. General plant and machinery from 21 years to 15 years; B. General furniture and fittings from 15 years to 10 years; C. Computers from 6 years to 3 years; D. Buildings other than factory buildings and other than RCC frame structure from approximately 58 years to 30 years; Also, useful lives have been prescribed for machinery used in the telecommunications business, manufacture of steel and non-ferrous metals, which were not laid down in Schedule XIV of the Companies Act, 1956. METHODS OF CHARGING DEPRECIATION The depreciation method used shall reflect the pattern in which the asset’s future economic benefits are expected to be consumed by the entity. The depreciable amount of an asset can be allocated on a systematic basis over its useful life through: A. straight-line method (SLM),or B. the diminishing balance method/ Reducing Value Method/ Written Down Value Method (WDV) That method is applied consistently from period to period unless there is a change in the expected pattern of consumption of those future economic benefits. In SLM, the amount of annual depreciation is calculated as: Capitalised Cost-Estimated Residual Value Estimated Useful Life In this method, the amount of annual depreciation remains uniform. On the other hand, in WDV Method, the amount of annual depreciation is calculated as: n 1- Estimated Residual Value Capitalised Cost Where n= useful life (in years) For first implementation for assets as on 01/04/2014, capitalized cost will be substituted by WDV as on 01/04/2014 and estimated useful life with remaining useful life. DEPRECIATION TREATMENT AS PER COMPANIES ACT, 2013 Name of the asset: Furniture & Fixtures Year of Original No of Depreciatio Net Residual Useful Remaining Amount Depreciati Acquisi Cost year n Carrying Value life Useful life to on tion used as Charged as Amount 5% of as per as on be to be of asset on on as cost CA 31/03/ charged provided 31/03/ 31/03/2014 on 2013 2014 to for 2014 @ 6.33% 31/03 Opening 2014-15 (Sch-XIV /2014 retain CA-1956) earnings/ Statemen t of Profit and Loss on 01/04/ 2014 (1) (2) (3) (4) (5)=2-4 (6)=2* (7) (8) (9)=5-6 5% 2002- (10)= (5-6)/8 10,000 11 6,963.00 3,037.00 500 10 0 2,537 10,000 10 6,330.00 3,670.00 500 10 0 3,170 10,000 9 5,697.00 4,303.00 500 10 1 3,803 10,000 8 5,064.00 4,936.00 500 10 2 2,218 03 200304 200405 200506 EFFECT OF CHANGE IN THE RATES OF DEPRECIATION FROM THE 1956 ACT TO 2013 ACT The following table illustrates the effect of change in the rates of depreciation from WDV rate of 40% and SLM rate of 16.21% under the 1956 Act, on an asset cost of Rs.1,000 and having 5% residual value, to a new useful life of 3 years under the 2013 Act. For determining the WDV rate under the 2013 Act, a computation would be required to arrive at the rate (63%), which would depreciate the asset to 95%: DEPRECIATION CHARGE AND WDV AS PER 1956 ACT DEPRECIATION CHARGE AND WDV AS PER 2013 ACT Beginning Written Depreciation Written Depreciation Written Depreciation Written Depreciation of Down charge as Down charge as Down charge as Down charge as per value per WDV value per SLM value per WDV value SLM Method @ under Method @ under Method @ under Method @ under 31.67% WDV 40% SLM 16.21% WDV 63% SLM Method Method Method Method Year 1 100 400 1000 162 1000 630 1000 317 Year 2 600 240 838 162 370 233 683 317 Year 3 360 144 676 162 137 87 366 316 Year 4 216 86 514 162 50 Year 5 130 52 352 162 Year 6 78 28 190 140 Year 7 50 50 50 EXTRA SHIFT DEPRECIATION No separate rates have been prescribed for extra shift depreciation. A blanket statement is provided that the period of time an asset is used in extra shift, depreciation will increase by 50% in case of double shift working and by 100% in case of triple shift working. An illustration showing the impact on single shift, double shift and triple shift depreciation after the introduction of Companies Act, 2013 is given below: A Ltd. is using Roll Grinder (falling in category of Plant and Machinery used in manufacture of non-ferrous metals in Schedule II) in its operation process. Details are as follows: Capitalised value of the Roll Grinder Rs. 5,00,000/- Useful Life prescribed in Schedule II 40 Years Residual Value Rs. 25,000/- Particulars Single shift Double Shift Triple Shift Depreciation Depreciation Depreciation Under Schedule XIV (Rs. 5,00,000)* 4.75% Rs.23,750 Rs. 37,100 Rs. 51,700 Rs.11,875 Rs.17,813 Rs.23,750 Rs.11,875 Rs. 19,287 Rs.27,950 (Rs. 5,00,000)* 7.42% (Rs. 5,00,000)* 10.34% As per the minimum rate Under Schedule II (Rs. 5,00,000-Rs. 25,000)* 2.50% (Rs. 5,00,000-Rs. 25,000)* 3.75% (Rs. 5,00,000-Rs. 25,000)* 5.00% Difference (Extra Depreciation under Schedule XIV) COMPONENT APPROACH Schedule II states that the useful life specified is for whole of the asset. However, where cost of a part of the asset is significant to total cost of the asset and the part’s useful life is different from the useful life of the remaining asset, useful life of that significant part shall be depreciated separately. This method of breaking a fixed asset into components for depreciation purposes is known as the ‘component approach’ to compute depreciation. Companies will now have to estimate the useful life of each such component (in case it is not provided in Schedule II) and depreciate the cost of that specific component over the estimated useful life. To apply the component approach, it is crucial to identify the various significant parts of an asset. There are two reasons for identifying the parts: Depreciation, and The replacement of parts. Generally, it is done by looking for items that will require replacement before the end of the asset's useful life, and to treat these items as separate components. Upon replacement of a part, the remaining book value of the replaced part is derecognised and the cost of the new part recognised, irrespective of whether the replaced part was depreciated separately or not. There is no minimum requirement for the number of parts of a fixed asset that should be identified. The number of parts may vary depending on the nature and the complexity of the fixed asset. Ind AS 16 requires each significant part of a fixed asset to be depreciated separately. Significant parts which have the same useful life and depreciation method may be depreciated together. Additionally, such parts that are individually not significant are combined in the remainder and are depreciated together. Componentization requires professional judgment. In many situations, a company may not have a good understanding of the cost of the individual components purchased. In that case, the cost of individual components should be estimated based on reference to: current market prices (if available), discussion with experts in valuation, or use of other reasonable approaches. It might also be considered necessary to request an expert opinion (for example, construction experts) in order to determine the parts of a fixed asset. This will also depend on the size of the organization and whether the component and related depreciation will have a material effect on the financial statements. For instance, the following practices are commonly used to identify the parts of a building: Exterior walls Interior walls Windows Roof Staircase Elevators Air condition Heating system Water system Electrical system Major inspections The following can also help in identifying components: Review plant maintenance programs. If the replacement of a component is significant enough to be listed on maintenance schedule, it may have a cost that is significant in comparison to the total cost of the asset; Review historical retirement patterns to evaluate what constitutes a component; Analyze major capital expenditures. However, the component accounting shall be voluntary in respect of the financial year commencing on or after the 1st April, 2014 and mandatory for financial statements in respect of financial years commencing on after the 1st April, 2015. MAJOR IMPACT 1. The useful life of an asset can be the number of production or similar units expected to be obtained from the asset. This indicates that a company may be able to use Units of Production (UOP) method for depreciation, which was previously prohibited for assets covered under Schedule XIV. 2. The application of component accounting is likely to cause significant change in accounting for replacement costs. Previously, companies needed to expense such costs in the year of incurrence. Under the component accounting, companies will capitalize these costs, with consequent expensing of net carrying value of the replaced part. 3. In case of revaluation, depreciation will be based on the revalued amount. Consequently, the ICAI guidance may not apply and full depreciation on the revalued amount is expected to have significant negative impact on the statement of profit and loss. This is a major change unnoticed at large. Dividend distribution and managerial remuneration may be significantly affected. 4. In case of assets with a nil remaining useful life on the date the Schedule II comes into effect, the transitional provisions require that the carrying amount may be charged to retained earnings. The word 'shall' has been replaced by the word 'may' by a beneficial notification which provides scope for charging the carrying amount in such case to revenue as well. This will be a welcome relief to companies subject to Minimum Alternate Tax. 5. Overall, many companies may need to charge higher depreciation in the P&L because of pruning of useful lives as compared to the earlier specified rates. However, in some cases, the impact will be lower depreciation, i.e. when the useful lives are much longer compared to the earlier specified rates. 6. The Companies will have to ascertain rates of depreciation for each individual item of fixed asset as on 01.04.2014 and the rate of depreciation may vary significantly depending on balance residual life as on the said date. This will be a very cumbersome exercise and proper maintenance of fixed asset register will be a pre requirement for the same. 7. Companies also need to assess the impact from implementation of Schedule II vis a vis depreciation as presently charged and disclose the financial impact of the same in Financial Statements. Thus for the first year depreciation both as per Companies Act, 2013 and Companies Act, 1956 needs to be calculated.