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Microlesson · 5-min read

Promoter, Expert & Chartered Accountant

# Promoter, Expert & Chartered Accountant

These three definitions cover outside professionals and architects of the company.

## 1. Promoter [Sec 2(69)]

A person who satisfies ANY one of:

#Test
(a)Has been named as such in a prospectus OR is identified by company in the annual return under Sec 92
(b)Has control over affairs of the company — directly or indirectly — whether as shareholder, director or otherwise
(c)Person on whose advice, directions or instructions the Board is accustomed to actEXCEPT where such person acts merely in a professional capacity

> Categories (b) and (c) catch de facto promoters who never appear on paper.

## 2. Expert [Sec 2(38)]

Inclusive definition — covers any person with power or authority to issue a certificate under any law in force, including:

  • Engineer
  • Valuer
  • Chartered Accountant (CA)
  • Company Secretary (CS)
  • Cost Accountant
  • Any other person with such power

## 3. Chartered Accountant [Sec 2(17)]

A Chartered Accountant as defined in Sec 2(1)(b) of the Chartered Accountants Act, 1949, who holds a valid Certificate of Practice (COP) under Sec 6(1) of that Act.

> Mere membership of ICAI is not enough — for the Companies Act, you must hold a valid COP.

Worked example

### Example 1

Q: Mr. P is the company's tax consultant; the Board sometimes follows his advice on tax matters. Is he a promoter under Sec 2(69)(c)?

A: No. Clause (c) expressly excludes persons giving advice in a professional capacity.

### Example 2

Q: A CA member of ICAI without a COP signs a certificate for a company. Is she a 'Chartered Accountant' under the Companies Act?

A: No. Sec 2(17) requires a valid Certificate of Practice under Sec 6(1) of the CA Act, 1949.

### Example 3

Q: A registered valuer issues a valuation certificate to a company. Is she an 'expert' under Sec 2(38)?

A: Yes — a valuer is expressly included.

⚠️ Common exam mistakes

  • Treating only persons named in prospectus as promoters — control-based promoters are also covered.
  • Including professional advisors (lawyers, CAs giving advice) as promoters — they are excluded.
  • Forgetting the COP requirement when calling someone a 'CA' under the Companies Act.
Bare-Act text Section 2(17), 2(38), 2(69) · Companies Act, 2013 · click to expand
Sec 2(69): 'Promoter' means a person — (a) who has been named as such in a prospectus or is identified by the company in the annual return referred to in section 92; or (b) who has control over the affairs of the company, directly or indirectly whether as a shareholder, director or otherwise; or (c) in accordance with whose advice, directions or instructions the Board of Directors of the company is accustomed to act: Provided that nothing in sub-clause (c) shall apply to a person who is acting merely in a professional capacity. Sec 2(38): 'Expert' includes an engineer, a valuer, a chartered accountant, a company secretary, a cost accountant and any other person who has the power or authority to issue a certificate in pursuance of any law for the time being in force. Sec 2(17): 'Chartered accountant' means a chartered accountant as defined in clause (b) of sub-section (1) of section 2 of the Chartered Accountants Act, 1949 who holds a valid certificate of practice under sub-section (1) of section 6 of that Act.
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