Para 4.9 of Guidance Note on Division III of Schedule III to the Companies Act, 2013

Paragraph 4.9 of the Guidance Note on Division III of Schedule III to the Companies Act, 2013 issued by the Institute of Chartered Accountants of India talks that the line items specified by Division III of Schedule III to the Companies Act, 2013 are minimum line items. It then says that line items specified by paragraph 54 and paragraph 82 of Ind AS 1 must be presented in addition to the line items specified by Division III of Schedule III. A plain reading of this paragraph would guide a reader to keep disclosing all the line items even if the same are not material. The paragraph misses to highlight the requirement of paragraph 31 of Ind AS 1 which clarifies that an entity need not provide a specific disclosure required by an Ind AS if the information resulting from that disclosure is not material except when required by law. It further clarifies that this is the case even if the Ind AS contains a list of specific requirements or describes tham as minimum requirements. Therefore, the line items specified in Division III of Schedule III must be presented only if they are material. Companies have been presenting line items with NIL amounts citing the reason that Guidance Note and Schedule III specify the requirements as minimum requirements. The guidance note must have clarified that though each of the divisions of schedule III state that the line items specified are minimum requirements, those line items must be presented only if material.

December 14, 2019