Monday, 29 June 2015

Key changes and issues in 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 applicable for the financial year commencing on or after 1 April 2011


•       Early adoption of the Revised Schedule VI not permitted since Schedule
VI is a statutory format


        Revised   Schedul VI  is  als applicabl to  consolidated   financial statements


        Except  in  the  case  of  the  first  financial  statements  laid  before  the company (after its incorporation), the corresponding amounts for the immediately preceding reporting period will also be given




        In case of conflict, requirements of the Companies Act, 1956 / Accounting Standards shall prevail over Schedule VI


        Information currently disclosed as schedules and notes to accounts now clubbed as notes to accounts



•      Consistency in definition of terms used, will carry the meaning as defined by the applicable Accounting Standards

•      Additional disclosures required by Accounting Standards and Act


•      By means of Notes, unless required on the face


•      A balance to be maintained between:  providing excessive details, not relevant; and not providing important  information as a result of too much aggregation

•    Balance Sheet abstract and general business profile dispensed with

      First year of application of Revised Schedule VI Comparatives to be given
Additional effort to recast comparatives

Auditors to perform procedures

Notes to disclose fact of reclassification / regrouping

Rounding Off




TURNOVER

EXISTING

REVISED

(Nearest figure or decimal thereof)

Less than Rs.100 crores

00’, 000

00’, 000
lakhs, millions

Rs.100 crores or more,  less than
Rs.500 crores

00’, 000’, lakhs, millions

00’, 000
lakhs, millions or crores


Rs.500 crores or more

00,000’, lakhs, millions or crores

00’, 000
lakhs, millions or crores


             •     Audit /Review report on interim financial statements


Para 10 and 11 of AS 25 Interim Financial Reporting:


     If an enterprise prepares and presents a complete set of financial statements in its interim financial report, the form and content should conform to the requirements as applicable to annual complete set of financial statements


     If an enterprise prepares and presents condensed financial statements in its interim financial report, its format should conform to that used in the companys most recent annual financial statements


•    General circular no 62/2011 dated 5 September 2011 issued by MCA


−     IPO/FPO after FY 2011-12 : the presentation of financial statements will be as per Revised Schedule VI





Report on financial information as per Clause 41- Revised Schedule VI

Format for statement of assets and liabilities


      Clause 41(V)(h) now prescribes format for the purposes of annual statement of assets and liabilities vide circular dated 16 April 2012.



Key Changes to Balance Sheets


      Revised Schedule VI prescribes a vertical format for presentation of balance sheet. Thus, a company will not have option to use horizontal format for presentation of financial statements.




•   Revised format-Key features

−   Indicates total assets

−   Indicates total equity and liability

−   Losses are reduced from equity

      Assets and liabilities are classified properly as 'Current' and 'Non-current', with non-current category being residual

−   No items like 'Misc expenditure to be written off'

An asset shall be classified as current when it satisfies any  of the following criteria:

      it is expected to be realized  in, or is intended for sale or consumption in, the entitys normal operating cycle;

•    it is held primarily for the purpose of being traded;

•    it is expected to be realized within twelve months after the reporting date;  or

      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.

Operating cycle  is the time between the acquisition of assets for processing and  their  realization  icash  or  cash  equivalents.  Where  the  normal operating cycle cannot be identified, it is assumed to have a duration of 12 months.

A liability shall be classified as current when it satisfies any of the following
criteria:

•   it is expected to be settled in the entitys normal operating cycle;


•   it is held primarily for the purpose of being traded;


•   it is due to be settled within twelve months after the reporting date; or


•   the entity 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.

                                                                                                                      
Example 1:


A company has taken a loan which is repayable on demand. However, based
on the past experience, it is not expected that the lender will demand the repayment within next 12 months.


Suggested Answer 1:


Since  the  company  does  not  have  an  unconditional  right  to  defer  the
settlement  of loan  for at least  12 months  after the reporting  date,  it will classify the loan as current. This is despite the fact that based on the past experience, it is not expected that the lender will demand the repayment within the next 12 months.




Example 2:


Company B has taken a 5 year loan. The loan contains certain debt covenants, e.g., filing of quarterly information. The company defaulted in filing of such information in the previous quarter, with the effect that loan has become repayable on demand. However, based on the past experience, the management believes that default is minor and the bank will not demand the repayment of loan.


Suggested Answer 2:


Ithe  borrower  does  nohave  unconditional  right  tdiffer  the  settlement,  the classification would be ‘Current. However as per the guidance note issued by the ICAI, considering that the practical implications of such minor breach are negligible in the Indian scenario, an entity could continue to classify such loan as ‘Non Current.



Example 3:


Employee benefit obligations in current and non-current categories.


Suggested Answer 3:


Liability toward bonus, etc., payable within one year from the balance sheet date is classified as current.


In case of accumulated leave outstanding as on the reporting date, the employees have already earned the right to avail the leave and they are entitled to avail the leave at any time during the year. Hence, it is disclosed as a current liability even if it is measured as other long-term employee  benefit.

Regarding funded post-employment benefit obligations, amount due for payment to the fund within 12 months created for this purpose is treated as current liability.


Regarding unfunded post-employment benefit obligations, a company will have settlement obligation at the balance sheet date or within 12 months for employees such as those who have already resigned or are expected to resign or are due for retirement within the next 12 months from the balance sheet date. Thus, the amount of obligation attributable to these employees is a current liability. The remaining amount attributable to other employees, who are likely to continue in the services for the next 12 months, 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.

Example 4:


Whether capital advances also need to be bifurcated between non-current
and current categories.


Suggested Answer 4:


Capital advances are advances given for procurement of fixed assets which
are non-current assets. Typically, companies do not expect to realize them in cash in the next 12 months or within their normal operating cycle. Rather, over the period, these get categorized as one or more fixed assets. Hence, we believe that capital advances should be treated as non-current assets and to be included in long term loans and advances.



Example 5:


A manufacturing company with a normal operating cycle of 18 months gives
a loan to a sister concern which is facing liquidity problem.  The loan is repayable 15 months after the reporting date.


Suggested Answer 5:


Giving of such loans is not a part of normal operating cycle of the company.
Further, the loan is not held for the purpose of being traded, nor is it cash or cash equivalent. The loan should be classified as non-current.

Example 6:


Company  A is  in  the  business  of  producing  wines.  The  manufacturing  process  entails  the inventory to be stored   in specified conditions for an extended period of time usually beyond twelve months so as to achieve the desired level of maturity, colour and taste. Whether the inventory of wines pending maturity as at the balance sheet date should be considered  as ‘current or ‘non-current for the purpose of Revised Schedule VI.?

Suggested Answer 6:

An asset shall be classified as current when it expected to be realized in, or is intended for sale
or consumption in, the entitys normal operating cycle. Operating cycle  is the time between the acquisition of assets for processing and their realization in cash or cash equivalents.

In the present case, the operating cycle is determined to be for a period beyond 12 months, hence inventory of wines which is expected to be consumed or realized within the operating cycle would be classified as current even though the inventory is not expected to be realized or consumed within twelve months after reporting date.

Where the normal operating cycle cannot be identified, it is assumed to have a duration of  12 months.





•    Notes in addition to the existing disclosures for share capital to be given:

    reconciliation  of  shares  outstanding  at  the  beginning  and  at  the  end  [Guidance  Note recommends disclosure of amounts]

    Number of shares held in respect of each class by holding company or ultimate holding company including shares held by or by subsidiaries or associates of the holding company or the ultimate holding company in aggregate

    No. of shares held by each shareholder holding more than 5% shares [Guidance Note recommends shareholding as on balance sheet date and for each class of shares]

 Shares reserved for issue under contracts / commitments

 Aggregate no. and class of shares bought back (for 5 years)

    Terms of any securities convertible into equity/preference  shares issued along with the earliest date of conversion in descending order, starting from the farthest such date.





•   Details pertaining to aggregate  number and class of shares allotted for
consideration other than cash, bonus shares and shares bought back will be disclosed only if such an event has occurred during a period of 5 years immediately preceding the balance sheet date

      Disclosure of unpaid calls (by showing aggregate of value of unpaid calls by Directors and Officers of the Company as defined by the Act)

•   Any  debit  balance  in  P&L  account  will  be  disclosed  under  the  head Reserves and surplus

•   Share options outstanding to be disclosed under reserves and surplus




     Specific disclosures are prescribed for the share application money. The application money not exceeding the capital offered for issuance and to the extent not refundable will be shown separately on the face of the balance sheet

•   Disclose

 Terms and conditions

 No. of shares to be issued and premium, if any

 Period by which shares to be allotted

 Whether sufficient authorised capital exists

 Period for which outstanding, beyond the stipulated allotment period

 Reasons for delays in allotment

 Interest accrued on amount due for refund

     The amount in excess of subscription or if the requirements of minimum subscription are not met will be shown under Other current liabilities





IN THE NOTES TO THE BALANCE SHEET:



      Bonds/debentures, with interest rate/terms for each loan, including amount of instalments due (in decreasing order of maturity/conversion starting from farthest redemption/conversion date)
      Period/amount of continuous defaults on Balance Sheet date in loans and interest
      Loans guaranteed by 'directors or others' unlike the present requirement of by 'directors or managers only'


Other Long term Liabilities Trade payable and others
      Amount dues under contractual obligation no longer included within trade payable






•   'Loan' has been used more in a more generic sense and is not restricted
like in CARO to borrowings from banks /financial institutions and debentures. Hence, details of default in repayment of loans and interest need to be disclosed for each of the items such as deferred payment liability,  deposit,  finance  lease  obligation,  etc  covered  under  the  head 'Borrowings'.


      Though the MCA has used two different terms, viz., continuing default  (in cas of   long-ter borrowing)   and   default   (i cas of   short-term borrowing), the requirement is to disclose default 'as on the balance sheet date' in both the cases. Any default that had occurred during the year and was subsequently made good before the end of the year is not required to be disclosed.



•     Short term borrowings

Further sub-classification

Disclosure as to defaults on Balance Sheet date in loans and interest

•     Trade Payables

Current  portion  of  payable  for  goods  purchased  or  services  received  in normal course of business

•     Other current liabilities

Further sub-classification

Disclosure of current portion of respective liabilities

Share application money due for refund

MSMED disclosure to continue



•   Classify 'provision for employee benefits' and 'others' (to specify nature)


•   No specific disclosure as to proposed dividend


       However, presently AS-4 requires provision for proposed dividend, and thus would override Schedule VI



•      Tangible fixed assets

Classification between tangible/non tangible

Office equipment, a new category

Assets under lease: specify under respective class of assets

Disclose business combination and impairments separately

•      Intangible fixed assets

Disclosure requirements similar to tangible assets

•    Capital work in progress relates to tangible fixed assets

•    Intangible assets under development

•    Other adjustment to include effect of AS11 and AS16




      Adjustment on account of revaluation/reduction in capital to be shown separately for a period of five years





•      Non current investments

AS-13 to prevail for current/non current classification

Non current investment to be classified as 'trade' and 'others'


•    Non current investments to further disclose:


−   Names of bodies corporate; showing separately partly paid investments

Bodie corporat includ 'subsidiaries' 'associates',   'join ventures'
'controlled special purpose entities (SPE)'.  SPE not defined
or


If investments in the capital of partnership firms: Name of the firm (with names of each partner, total capital and  shares of each partner)

the


•    INVESTMENTS PURCHASED/SOLD DURING THE YEAR:

−   DISCLOSURES NO LONGER REQUIRED





•     Long term loans and advances


Capital advances


Security deposits


Loans and advances to related parties


Others


•     Sub-classification as secured/un-secured/doubtful, to continue



        The term 'sundry debtors' has been replaced with the term 'trade receivables'.    CA 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, which were earlier included in the sundry debtors, can no longer be included in the trade receivables.


        Pre-revised Schedule VI required separate presentation of debtors (i) outstanding for a period exceeding 6 months (i.e., based on billing date) and (ii) other debtors, in a schedule to the balance sheet. However, Revised Schedule Vprescribes the following disclosure for trade receivables only under the head 'current assets':


        'Aggregate  amount of trade receivables  outstanding  for a period exceeding  six months from the date they are due for payment should be separately stated.'


•        Cash and cash equivalents shall be classified as:


Balances with Banks;


Cheques, drafts on hand;


Cash on hand;


Others (specify nature).



        Earmarked  balances  with  banks  (for  example,  for  unpaid  dividend)  shall  be  separately stated.

        Balances with banks to the extent held as margin money  or security against the borrowings, guarantees, other commitments shall be disclosed separately.

        Repatriation restrictions, if any, in respect of cash and bank balances shall be separately stated.

•      Bank deposits with more than 12 months maturity shall be disclosed separately


      In  the  earlier  Schedule  VI,  details  of  capital  commitments  were  required  to  be disclosed. Under the Revised Schedule VI, all commitments need to be disclosed


•    The word commitment is not defined in the Revised Schedule VI.


Guidance Note to Revised Schedule VI: Para 8.8.7.6 states that disclosures required to be made for other commitments should include only those non-cancellable contractual commitments. (i.e. cancellation of which will result in a penalty disproportionate to the benefits involved). Example: Commitments in the nature of :

buy-back arrangements;                       

 to fund subsidiaries and associates;

 non-disposal of investments in subsidiaries and undertakings;

 derivative related commitments



•     Statement of Profit and loss account

        Revised format of P&L account does not list any appropriation on its face as below the line adjustments i.e. bonus shares, dividend and transfer to/from reserves are to be presented under 'Reserves and Surplus' in the balance sheet. Amount set aside/proposed to be set aside needs to be disclosed as additional information in the notes.

        The classification of expenses is based on their nature and not on their function.

        In addition to specific disclosures prescribed in the P&L account, any item of income or expense which exceeds 1% of the revenue from operations or `100,000, whichever is higher, needs to be disclosed separately.

        Exceptional extraordinar and   prior   period   items   to   be   disclosed separately on the face of P&L account.

•     The  Revised  Schedule  VI  requires  a  company  other  than  a  finance
company to disclose breakup of revenue by way of a note as


Sale of products

Sale of services

Other  operating revenues - Sale of by-products or scrap in a manufacturing company

Less excise duty

        AS 9 Revenue recognition requires turnover to be disclosed in the following manner on the face of the profit and loss account

Turnover (gross)

Less excise duty

Turnover (net)

•      Breakup of other income by way of a note as

Interest income (other than a finance company)

Dividend income (dividend from subsidiary to be shown separately), principles of AS 9 to be followed

Net gain/loss on sale of investments

Other non operating income (net of expenses directly attributable)


Guidance Note to Revised Schedule VI:

   Sale of Fixed Assets is not an operating activity of a company and hence profit on sale of fixed assets should be classified as Other Income. Similarly sale of scrap arising from operations for a manufacturing company should be treated as Other Operating Income since the same arises on account of the companys main operating activity.

    In  the  first  year  of  application  of  Revised  Schedule  VI,  dividend  income  recognized  in  the  immediately preceding year based on the aforesaid requirements of Pre-revised Schedule VI should not be derecognized for the comparatives presented

    Net foreign exchange gain should be classified as Other Income. Any gains / losses on account of foreign exchange fluctuations are to be disclosed separately.



        Dividend in foreign currencie along with other details viz. information relating to the  number  onon-resident  shareholders  and  the  number  of  shares  held  - information is required to be given in the year of actual payment of dividend rather than in the year in which the dividend is proposed or declared


•      Share of profit or loss in a partnership firm / AOP / LLP


No  specific  requirement  iRevised  Schedule  VI,  share  of  profit  oloss  in  a partnership  firm  should    be  accounted  for  athe  time  same  is  computed  and credited or debited to the Capital/Current/any other account of the company in the books of the partnership firm.
The  above  accounting  also  applies  to  the  share  of  profits  and  losses  in  an
Association of Persons (AOP).
Share of profit/loss in a LLP should be accounted in the books of the company as and when the same is credited/ debited to the Partners’ Capital Account as per the terms of the LLP Agreement

 Employee Benefits expense should be disclosed separately as:
 Salaries and wages
 Contribution to provident and other funds
 Expense on ESOP and ESPP
 Staff welfare expenses


 Payments to auditor as:
Auditor
taxation matters
company law matters
management services
other services
reimbursement of expenses



Guidance Note to Revised Schedule VI:


      Penalties and other similar amounts paid to the statutory authorities are not strictly in the nature of 'contribution' and should not be disclosed under Employee Benefits.



Tax Expenses


As per Guidance Note to Revised Schedule VI


   Any interest on shortfall in payment of advance income-tax is in the nature of finance cost and hence should not be clubbed with the Current tax. The same should be classified as Interest Expense under Finance Costs. However such amount should be separately disclosed.


   Penalties levied under Income Tax laws should not be classified as Current tax. Other tax penalties should be classified under Other Expenses.


   Wealth  tax  payable  by a company  oassets  liable  fowealth  tax should  not be included within Current tax since the same is not a tax on income. Accordingly it should be included in Rates and Taxes under Other Expenses.


        The pre-revised Schedule VI required the parent company 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.


•      Such requirement no longer exists  in Revised Schedule VI. Accordingly, as per AS 9
Revenue Recognition, dividends should be recognized as income only when the right to receive dividends is established by the balance sheet date.


        Disclosure relating to provision for losses of subsidiary companies should be made separately only where such a provision has been made in respect of the investment in such loss-making subsidiary.

•   Disclosures no longer required


−    Income split between trade and other investments


−    Nature of interest income


−    Tax Deducted at Source disclosure for investment income


−    Profit/loss on account of membership of partnership firm


     Disclosures  relating  to  managerial  remuneration  and  computation  of  net  profits  for calculation of commission

−     Information relating to licensed capacity, installed capacity and actual production.


     Investments, sundry debtors and loans & advances pertaining to companies under the same management

     Commission, brokerage and non-trade discounts (But if it exceeds 1% of the revenue from operations or `100,000, whichever is higher, then same needs to be disclosed separately)





        Break-up in terms of quantitative disclosures for significant items of P&L account such  aramaterial  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 materiality and presentation of true and fair view of the financial statements.





Nature of company
Disclosures required
Manufacturing companies
 Raw materials under broad heads
 Goods purchased under broad heads
Trading companies
 Purchases of goods traded under broad heads
Company that falls in more than one category
   It  will  be  sufficient  compliance  with  the  requirements,  if purchases, sales and consumption of raw material are shown under broad heads



Disclosures required are quite ambiguous

•     Whether a company is required to disclose quantitative details or not


        Whether a manufacturing company will disclose purchase, sale or consumption of raw material


•     What is meant by 'good purchased' in case of manufacturing companies?


        While there is a requirement to disclose sales in case of a company falling in more than one category, there is no clear requirement to disclose sales for a manufacturing or a trading company


        With  regard  to  a  company  falling  in  more  than  one  category  2-3  different interpretations seem possible. One interpretation is that it should disclose purchase, sale and consumption for raw material. The other interpretation is that purchasrelates to traded goods, sale relates to all goods sold (both manufacture good an trade goods an fo raw   material only consumptions needs to be disclosed



Conflict between Revised Schedule VI and AS 3


•      Definition of cash and cash equivalents’ as per AS 3 :

Cash comprises cash on hand and demand deposits with banks and cash equivalents are short term, highly liquid investments that are readily convertible into known amounts of cash and that are subject to an insignificant risk of changes in value

        An investment normally qualifies as a cash equivalent only when it has a short maturity of three months or less from the date of acquisition

•      Classification of ‘balances with banks’:

(Accounting Standards prevail over the Revised Schedule VI)

a)    Under Cash and cash equivalents if they are demand deposits or have original maturity of three months or less

b)  Under a separate sub-heading ‘Other bank balances if they are due for realization within
12 months of the reporting date and do not qualify for classification under cash and cash equivalents

c)  As a separate heading under ‘other non-current investments’/ ‘other non-current assets’, if they are not due for realization within 12 months of the reporting date


Implementation issues:-


•    First step of a ‘mind-set’ change.

      Legality of the amendment. Can Schedule VI be amended in isolation without any notifications?
      Substantial efforts required by companies to recast and auditors to audit previous reporting periods figures
      Challenges faced whilst preparing consolidated financial statements as per Revised Schedule VI for entities which have a large number of subsidiaries, associates and joint ventures in such a short duration.
•    Share Capital (Para 6A):

−     Disclosure of shareholding of each shareholder holding more than 5% of share capital will result in making the disclosure voluminous and the annual report bulkier
−    Challenges in getting information from Depository Participants, GDR / ADR custodians

•    Long-term borrowing (Para 6C)

−     Lack of clarity whether the long-term borrowings will get covered for the purposes of determining limits u/s 293(1)(d).

•     Non-Current Investments (Para 6K)

−    Clarification required for nature and definition of 'Controlled Special Purpose Entity'. Para
8.7.2.4 of the Guidance Note issued by ICAI is vague

(The position has been revised in the final guidance note vis-à-vis draft guidance note. It states as follows:

−     No disclosure would be additionally required to be made under this caption. If and when the terminology is explained / introduced in the applicable accounting standards, disclosure requirement would become applicable.

−     The analogy drawn from AS 21 has been removed)

−    Detailed disclosures relating to investment in partnership firms

•    Long-term Loans and Advance (Para 6L)

−    Advance Tax whether to consider as current or non-current asset

Implementation Issues - IT / ITES


IT / ITES companies are involved in development of software that are used for providing services

      Separate disclosure for 'Intangible assets under development' such development of certain software, etc in Fixed Assets provided they can be recognized based on the criteria laid down in AS 26 -  Intangible Assets




Classification  of MAT Credit and Service Tax credit into 'current' and 'non current' Income is exempt  u/s 10AA of Income-tax Act, 1961 and output services are tax exempt, hence input credit remains accumulated due for refund
•   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




Other commitments in note  to accounts to include only non-cancellable contractual commitments

      Professional judgment is required for the commitments such as contracts with customers, commitments to fund subsidiaries etc to be disclosed which are material and relevant to understanding of the financial statements.


Implementation Issues Pharmaceutical


Research  and  development  (R&D)  arrangements  are  entered  wherein  initial  amounts  are received

      Upfront payments made / received in pursuance of such collaboration arrangements would further require analysis for 'current'/ 'non current' classification




Contingent liabilities and commitments
-

      Contractual arrangements such as arrangement with third party manufacturer, etc need to be evaluated
      Commitments  made  under  research  and  development  contracts  that  may  result  in acquisition of intangible assets may need to be disclosed under 'other commitments'


Implementation Issues - FMCG


Trade receivables due for a period more than six months should be identified based on ‘due date’
and not ‘invoice date.

      FMCG companies have large number of customers, the Company needs to define credit terms for all customers
•   In  absence  of  due  date  specifically  agreed  upon,  normal  credit  period  allowed  by the
Company should be considered

      Normal credit period may vary depending upon the nature of goods or services sold and the type of customers

Implementation issues - Power


Classification of upfront premium paid for acquisition of project rights

•     Evaluate classification of project rights as ‘intangible assets under development



Classification of current and non current

•     Evaluation of retention payable during the course of the project for classification as current /
‘non current

Disclosure for other commitments in notes to accounts

•     Evaluation for disclosure of commitment for acquiring of renewable purchase obligations

Implementation Issues Telecom Industry specific

•      Security deposit:-Classification  of the security deposit collected from its customers (retail and wholesale segment) between current and non-current will throw-up significant challenges in terms of collation of the informatio(challenges would also include recognitioat the time of inception of receipt of deposit).The similar challenges would be faced in the deposit placed with
landlords for site/premises acquired.
•      Deferred Revenue:-As per revised schedule VI deferred revenue recognized as a result of the upfront payment is classified as current even if the related service is not expected to be performed within 12 months of the reporting date.  This requirements needs to be considered in conjunction with businesses (for e.g sale of IRU, etc.) where it is normal to receive customer payments in advance.

Effect on profit and loss account:
•      The revised Schedule VI mandates disclosure of revenue from : a) Sale of products b) sales of services c) other operating revenue d) less: excise duty. Telecom companies enter into various revenue  arrangements  involving  sale  of  multiple  components/bundled  contracts.  rigorous process of estimation (to provide disaggregated disclosures between sale of services and goods) is involved in bifurcating the revenues between various component (sale of services and goods), would pose a significant challenge.

MCA Due Dates

MCA Compliance Due Dates. It may me differ if MCA extends above due dates.