Excise Audit Scheme (EA-2000) - Further guidelines for implementation
Circular
No. 514 dated 16th February 2000
It
is a directed to say that certain views have been expressed by various
Commissionerates regarding implementation of the Excise Audit-2000 (EA-2000).
The initial guidelines are contained in Board�s Circular No. 491/57/99-CX.6
dated 28th of October 1999. The views of the Commissionerate are
categories as follows:
Data
management for Audit preparations;
Audit
Report format;
Total
period of the Audit;
Evaluation
of the Audit Report through a scoring system;
System
of institutionalised monitoring;
Training;
Availability
of computer; and
Audit
of units between Rs. 1 crore and Rs. 5 crore revenue.
Assessee
Profile (database)
The
first view expressed was that data must be collected by all Commissionerates in
a standardised format so that only absolutely essential information relevant for
the conduct of audit is collected. This standardised collection would also
facilitate maintenance of a computerised database al l over the country. In this
connection, Standardised Format for Assessees Profile has been devised to serve
as a standard for collection of data relevant for Excise Audit-2000, which is
enclosed as Annexure-I.
In
addition to this, it would be of advantage to the Department to know certain
critical ratios relating to an assessees factory/ business from the data
available in the Balance Sheets (Annual Reports) of the assessee/ Assessees
profile/ Other Reports before the audit is contemplated. For example, raw
material cost: sale value, discount; sale, outward freight: sale, power
consumption (units): production quantity, change in profit: assessable value
etc.. The officers of the Audit Wing may be trained to derive these ratios.
These ratios, wherever possible, should be studied at the time of "Desk
Review".
The
Assessees profile and the ratios will serve as a useful database for the conduct
of �Desk Review�, which is the first step in the Audit Programme explained
in both the Excise Audit Manual and the Standard Audit Programme. Needless to
mention a comprehensive database would help in proper preparation for conduct of
Audit.
: The
Audit Manual speaks about completion of an Audit Report (Chapter 8). No format
of the Audit Report has been provided. It is important that the Audit Report
findings are standardised. Keeping in view the need to ensure brevity and
objectiveness, a standardised format has been prepared which is enclosed at
Annexure-II. The Audit Report format particularly focuses on action on old audit
points; the summary of the audit objections along with reasons and important
points for future compliance. This must be prepared after finalisation of the
Working Papers. The Audit Report should also substantiate findings, drawing from
material in the Working Papers. Both these documents should be put in computer.
:Every Audit
undertaken must have a reasonably defined timeframe. This would also help to
bring in the much-needed discipline in the conduct of audit. Keeping in view the
fact that EA-2000 requires more pointed audit of financial records it has been
decided that the total time limit for the conduct of audit and submission of the
audit report should not exceed 20-25 days from the commencement of the Audit in
the Assessees unit.
: One
of the keys to good audit is a system of good monitoring and evaluation of audit
reports. EA-2000 makes this task easier by prescribing that all audit work must
be clearly documented in the Working Papers. Senior officers at the level of
Joint Commissioner/ Additional Commissioner must evaluate these Working Papers.
After due deliberation, a scoring system has been evolved which may be used to
evaluate an audit report which consists of the Working Papers, the Summary sheet
(part of the Working Papers) and the Audit report itself. The Scoring system
which is enclosed as Annexure-III divided the entire process of Audit into five
parts: (I) preparation of the audit plan; (ii) conduct of audit; (iii) revenue
points raised (major objections and their quality); (iv) realisation of revenue,
and (v) issues relating to future compliance by the company. The scoring system
has been devised so as to give greater emphasis on the conduct of the audit,
which is extremely important in the initial stages of the implementation of the
new Audit system. A greater responsibility, therefore, rests on the senior
officers to duly assess the reports and bring out the strength and weaknesses of
the audit reports. A quantities system of measurement would help in steering the
audit into areas, which are the core of the new Audit system. It is however,
clarified that the scoring system is not meant for reprimanding any officer(s)
or fixing any responsibility. It is meant for providing in-built synergic system
so as to correct the weaknesses at the initial stages.
In
the Board�s Circular No. 491/57/99-CX.6 dated 28th of October, 1999
it was suggested at Para 18 that an Excise Audit Monitoring Cell be constituted
headed by the Commissioner. It must be ensured that the Monitoring Cell meets
once a fortnight and also specially examines in the audit report important
points raised. Assistant Commissioner/Deputy Commissioner/Joint
Commissioner/Additional Commissioner (Audit) should meet all the Audit Parties
at least once in a month to review their functioning and ensure the exchange of
information among the audit parties.
: To
start with, a copy of the score sheet should be forwarded to DG (AE) as soon as
it is ready. A suitable device will be worked out for seeing the Audit Reports
for Rs. 5 crores and above units; selectively in due course.
:
Audit Protocol is a limited initiative within the overall EA-2000. Out of the
eight corporate with whom discussions had been held, five, namely, Indian Oil
Corporation, Maruti Udyog Ltd; TISCO, Steel Authority of India Ltd. And
Hindustan Lever has already singed Protocol. MRF has given a letter agreeing to
sign the Protocol. As stated in Chairman�s letter on Audit Protocol, Assistant
Director (Cost) must accompany the audit teams for Protocol audits. In case the
Commissionerate does not have an Assistant Director (Cost), the AD (Cost) from
any Commissionerate within the zone should be a part of the audit team.
:
Normally, for all Rs. 5 crores and above units, AD (Cost) should, as far as
possible, be also involved in audit.
:
The success of Ea-2000 is critically dependent on the requisite training
imparted to Auditors. Since in a number of Commissionerates the Audit teams have
not been exposed to any training on Accountancy, it is necessary, keeping in
view the emphasis being placed on scrutiny of business records, that
Commissioners ensure that this training programme on Accountancy is organised
for staff not covered so far. The faculty may be drawn either from serving
officers like AD(Cost). Such training should have a practical orientation so
that the lectures are linked to practical application, which is necessary to
sustain interest.
:
It is learnt some of the Commissionerates have not been able to provide a
computer to Audit Branch. This should be done priority basis.
Field
formations may be suitably informed. Any difficulties noticed in this regard may
be brought to the notice of the Director general (Anti-Evasion) immediately.
ANNEXURE-I
Assessee
Profiles for Ea-2000
1.
Name of the Assessee:
2.
Registration Certificate No.:
3.
New ECC No.:
4.
General Details:
PART-I
Serial No.
|
Description
of Goods manufactured
|
Tariff
sub-heading
|
Exemption
Notification availed
|
Rate
of Duty
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
PART-II
Year
|
Personal
Ledger Account
|
Modvat
Account
|
Total
duty payment
|
|
|
RG23A
| RG23C
|
|
|
|
|
|
|
|
|
|
5.
Commodity-wise details
Commodity
/Year
|
Production
|
Clearance
for home consumption
|
Qty.
Value
|
Clearances
forgoing duty
|
Exports
Imports
|
Qty.
Value
|
Qty.
Value
|
Duty
debited in PLA
|
Duty
debited in RG23A/RG23C
(Total)
|
Payment
from Modvat account as Percentage of Total duty paid
|
(1)
|
(2)
|
(3)
|
(4)
|
(5A)
|
(5B)
|
(5C)
|
(5D)
|
(6)
|
(7)
|
(8)
|
Commodity-I
1996-97
1997-98
1998-99
|
|
|
|
|
|
|
|
|
|
|
Commodity-2
1996-97
1997-98
1998-99
|
|
|
|
|
|
|
|
|
|
|
Commodity-3
1996-97
1997-98
1998-99
|
|
|
|
|
|
|
|
|
|
|
6.
Major Input and Output in the Modvat declaration.
Declaration
made under Rule 57G/in respect of 57A inputs.
Sl.No
|
Input
|
Final
Product
|
|
|
|
|
|
|
|
|
|
Major
item/ sub-heading declared as Capital Goods under Rule 57Q.
Major
Audit Points:
Serial
No.
|
Present
Status
|
Commodities
|
Duty
involved
|
Issue
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Major
Preventive Points:
Serial
No.
|
Present
Status
|
Commodities
|
Duty
involved
|
Issue
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
10.
Marketing pattern, clearance pattern etc.
Sl.
No.
|
Nature
of Sale/Transfer Etc.
|
Yes
|
No
|
If
Yes, Description of Products (s)
|
1.
|
Sale
at the factory gate
|
|
|
|
2.
|
Sale
through the depot/distributors/consignment agents/ Marketing
intermediaries.
|
|
|
|
3.
|
Sale
in retail
|
|
|
|
4.
|
Retail
Sale Price (Maximum)-Section 4A
|
|
|
|
5.
|
Inter
plant transfer
|
|
|
|
6.
|
Captive
Consumption
|
|
|
|
7.
|
Clearance
to U.N. and other aided projects
|
|
|
|
[These
details must tally with the declaration given by the assessee in the Declaration
specified under sub-rule (3A) of rule 173C of the Central Excise Rules, 1944]
ANNEXURE-II
Audit
Report Format For EA-2000
PART-I
1)
Name of the unit:
2)
Commissionerate/Division/ Range in which it is located:
3)
Products manufactured:
4)
Tariff Item:
5)
List of main exemption Notification:
6)
Date of last audit:
7)
Period for which current audit undertaken:
8)
Dated on which audit undertaken:
PART-II
Summary
of major audit objections from the Working Paper:
Sl.
No.
|
List
of Objection
|
Revenue
implicated, if any
|
Assessee
Agreement Yes/No if no, reasons for disagreement
|
Department�s
conclusions with reasons
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Revenue
Law Times
Suggestions
for better compliance including systemic improvements and notifications in the
legal arrangements:
Assistant
Commissioner/Deputy Commissioner/Joint Commissioner/ Additional Commissioner
(Audit)
ANNEXURE-III
Scoring
system for EA-2000
1)
Name of the Unit:
2)
Commissionerate/ Division:
3)
Range in which it is located:
4)
Constitution of the Audit Party:
(with Names and Designation of the
Officers)
5)
Reference to the Audit Report takenfor this
Scoring:
Areas
|
Points
(Maximum)
|
Sl.
No. on Working Papers
|
(a)
Quality of Audit Plans
|
15
|
Point
No. 7
|
(b)
Systematic conduct of Audit with a view to taking and integrated ad
comprehensive look at the systems especially those which have a bearing
on revenue compliance
|
50
|
Points
1to 6 and 8 (within this evaluation of Internal Control could be
assigned 20 points)
|
(c)
Revenue points flowing from finalisation of Audit
|
15
|
Point
9&10
|
(d)
Recovery of Audit Assessments
|
10
|
Point
11
|
(e)
Suggestion for better compliance including systemic improvements and
modifications in the legal arrangements.
|
10
|
Point
12
|
|
100
|
|
|