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Microlesson · 5-min read

Appointment of Auditors – Section 139

# Appointment of Auditors [Section 139]

The appointment process differs between Government companies (controlled by Government) and non-Government companies.

## (A) First Auditor

### Non-Government Company [Section 139(6)]

StepAuthorityTimeline
1BOD appointsWithin 30 days from date of registration
2If BOD fails → inform members; members appoint at EGMWithin next 90 days
TenureFirst auditor holds office until conclusion of 1st AGM

### Government Company [Section 139(7)]

StepAuthorityTimeline
1CAG appointsWithin 60 days from date of registration
2If CAG fails → BOD appointsWithin next 30 days
3If BOD fails → inform members; members appoint at EGMWithin next 60 days
TenureFirst auditor holds office until conclusion of 1st AGM

## (B) Subsequent Auditor

### Non-Government Company

  • BOD recommends name to members.
  • Members appoint by passing an Ordinary Resolution (OR) at the AGM.
  • Term: From conclusion of 1st AGM to conclusion of 6th AGM (i.e., 5 years).

### Government Company

  • CAG appoints the subsequent auditor within 180 days from commencement of the FY.
  • Auditor holds office till conclusion of the next AGM (i.e., 1-year term).

## (C) Casual Vacancy

A casual vacancy is one arising other than by expiry of term (e.g., death, resignation, disqualification).

### Non-Government Company

  • BOD fills the casual vacancy within 30 days.
  • Auditor holds office until conclusion of next AGM.
  • If vacancy arose due to resignation, appointment must also be approved by members via OR at a general meeting convened within 3 months of BOD's recommendation.

### Government Company

  • CAG fills casual vacancy within 30 days.
  • If CAG fails → BOD fills within next 30 days.
  • Auditor holds office till conclusion of next AGM.

## (D) Recommendation Process for Subsequent Auditor

### Where Audit Committee Is Required (Section 177)

1. Audit Committee recommends name to BOD.

2. If BOD agrees → recommends to members for appointment at AGM.

3. If BOD disagrees → refers back to Audit Committee with reasons.

4. If Audit Committee does not reconsider, BOD records its reasons and sends its own recommendation to members.

### Where Audit Committee Is Not Required

  • BOD itself recommends name to members for appointment at AGM.

## (E) Companies Required to Constitute Audit Committee [Section 177]

  • Listed public company, AND
  • Unlisted public company having (as on date of last audited FS):
  • Paid-up capital ≥ ₹ 10 crores, OR
  • Turnover ≥ ₹ 100 crores, OR
  • Aggregate outstanding loan, borrowing, debenture & deposit > ₹ 50 crores.

Exit clause: A company is exempted from constituting the Audit Committee if it was earlier required but ceases to fulfil the conditions for 3 consecutive years.

## (F) Conditions Before Appointment

Before appointing an auditor:

1. Obtain written consent from the auditor.

2. Obtain a certificate from auditor stating:

  • He is eligible & not disqualified (criteria under Section 141 satisfied),
  • Appointment is within the prescribed limits (e.g., 20-company ceiling),
  • Appointment is as per terms under the Act,
  • List of proceedings against the auditor/firm/partner for professional matters of conduct is disclosed and is true & correct.

## (G) Filing Requirements

  • Company shall inform the auditor about appointment.
  • File Form ADT-1 with ROC within 15 days of the meeting where the auditor was appointed.

Worked example

### Example 1

Example: First Auditor of a Non-Government Company

XYZ Ltd. (non-government) was incorporated on 1st April 2025. The BOD did not appoint a first auditor within 30 days.

Analysis:

  • BOD's window (30 days from registration) expired on 30th April 2025.
  • BOD must now inform the members; members can appoint within 90 days at an EGM.
  • The first auditor so appointed will hold office till the conclusion of the 1st AGM.

Conclusion: XYZ Ltd. must convene an EGM by 29th July 2025 (within 90 days) for members to appoint the first auditor.

⚠️ Common exam mistakes

  • Mixing up timelines for first auditor appointment: Non-Gov Co = 30 days (BOD) / 90 days (members at EGM); Gov Co = 60 days (CAG) / 30 days (BOD) / 60 days (members at EGM).
  • Forgetting that for Government companies, the subsequent auditor is appointed by CAG, not by members in AGM.
  • Forgetting the member ratification requirement for casual vacancy caused by resignation in non-government companies.
  • Confusing the term of first auditor (till 1st AGM) with that of subsequent auditor (1st AGM to 6th AGM, i.e., 5 years).
  • Forgetting to file Form ADT-1 within 15 days with the ROC after appointment.
  • Confusing Audit Committee thresholds: paid-up ≥ ₹ 10 cr, turnover ≥ ₹ 100 cr, outstanding loan/borrowing/debenture/deposit > ₹ 50 cr.
  • Ignoring the 3-consecutive-year exit clause for Audit Committee requirement.
Bare-Act text Section 139 · Companies Act, 2013 · click to expand
Section 139 — (1) Every company shall, at the first annual general meeting, appoint an individual or a firm as an auditor who shall hold office from the conclusion of that meeting till the conclusion of its sixth annual general meeting and thereafter till the conclusion of every sixth meeting... (5) In the case of a Government company..., the Comptroller and Auditor-General of India shall, in respect of a financial year, appoint an auditor duly qualified to be appointed as an auditor of companies under this Act, within a period of one hundred and eighty days from the commencement of the financial year... (6) The first auditor of a company, other than a Government company, shall be appointed by the Board of Directors within thirty days from the date of registration of the company...
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