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Microlesson · 5-min read

Audit of Income – RBI Materiality Directions and Reversal of Income

## Audit of Income in Banks

### (i) RBI Direction on Materiality and Basis of Recognition

Income recognition basis depends on whether the income is material:

TestIf Met → Basis
Any income item > 1% of Total Income of the bankAccrual basis (Gross Basis)
Any income item > 1% of Profit Before Tax of the bankAccrual basis (Net Basis)
Income is not material (below both thresholds)Bank may recognise on Cash Basis

> Material income must always be recognised on an accrual basis. Immaterial income can optionally be on cash basis.

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### (ii) Reversal of Income (Very Important)

#### General Rule

When any advance (including bills purchased and discounted) becomes NPA:

  • Interest accrued but not received must be reversed.
  • This reversal also applies to Government Guarantee Advances (not just regular advances).

#### Commission and Similar Income

In respect of NPA accounts:

  • Commission and similar income that has accrued should cease to accrue in the current period.
  • Past accrued but uncollected amounts must also be reversed.

#### Interest Income Wrongly Booked in Current Year

If interest income was incorrectly booked in the current year:

1. Reverse the interest income; AND

2. Make a provision for an equal amount of the income recognised in the current year.

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### (iii) Auditor's Specific Inquiry

  • Inquire about large debits in the Interest Income account that are unexplained.
  • Inquire whether communication was made to the borrower about any difference in interest charged (i.e., reconciliation with borrower's records).

Worked example

### Example 1

Materiality Test for Income Recognition Basis:

Bank's Total Income = ₹500 crore.

Profit Before Tax = ₹80 crore.

1% of Total Income = ₹5 crore.

1% of PBT = ₹80 lakh.

Income item A = ₹6 crore → Exceeds 1% of Total Income → Must be recognised on Accrual (Gross) Basis.

Income item B = ₹1 crore → Exceeds 1% of PBT but < 1% of Total Income → Recognised on Accrual (Net) Basis.

Income item C = ₹50 lakh → Below both thresholds (< ₹80 lakh) → Bank may use Cash Basis.

### Example 2

Reversal of Income on NPA:

A term loan account becomes NPA on 01-Oct-2024.

Interest accrued from 01-Jul-2024 to 30-Sep-2024 = ₹1,20,000 → Already credited to Interest Income.

Interest from 01-Oct-2024 to 31-Mar-2025 = ₹2,40,000 → Should NOT be accrued.

Audit finding: Bank has continued to book ₹2,40,000 as income after NPA date.

→ Auditor requires: (1) Reverse ₹2,40,000 from Interest Income, AND (2) Make a provision of ₹2,40,000.

Also: The ₹1,20,000 already booked for the pre-NPA quarter should be reversed if not collected.

⚠️ Common exam mistakes

  • Thinking the reversal of income on NPA applies only to new NPAs — it applies to all NPAs, including accounts that became NPA in prior periods if income was erroneously booked.
  • Forgetting that the reversal rule applies to government guarantee advances — the guarantee doesn't make the advance immune from the income reversal requirement.
  • Assuming immaterial income must be on cash basis — the RBI rule says bank 'may' use cash basis for immaterial income; it is permitted but not mandatory.
  • Reversing income without also making an equal provision when the income was wrongly booked in the current year — both steps (reversal + provision) are required together.
  • Applying the 1% materiality test only to the Total Income threshold — there are two independent tests (1% of Total Income OR 1% of PBT); income exceeding either threshold must be on accrual basis.
Reference: Para on Income Recognition — RBI Master Circular on Prudential Norms on Income Recognition, Asset Classification and Provisioning
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