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Microlesson · 5-min read

Audit of Share Capital — Verification, Premium, Discount, Sweat Equity, Reduction

# Audit of Share Capital

## 1. General Share Capital Verification

  • Tally the opening balance with prior year figures; trace all movements during the year.
  • No change in SC: Obtain Written Confirmation from the Company Secretary (CS).
  • Change in SC: Verify paid-up capital does not exceed authorised limit; check MOA/AOA accordingly.

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## 2. Fresh Issue of Shares — Compliance Checklist

For every fresh issue, the auditor checks compliance with the Companies Act and applicable regulations:

ItemWhat to Check
Return of AllotmentFiled with MCA
Minimum SubscriptionReceived before allotment
Underwriting CommissionPaid within prescribed limits
Consideration other than cashProperly valued and disclosed
DiscountNot issued at discount (check exceptions)
Stamp DutyCorrectly calculated and paid to MCA
SEBI RegulationsComplied with (for listed companies)
Form FCGPRFiled with RBI for FDI by NRI

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## 3. Issue at Premium — Section 52, Companies Act 2013

Securities Premium Account (SPA) can only be applied for these five purposes:

1. Writing off preliminary expenses

2. Writing off expenses, commission, or discount on issue of shares/debentures

3. Issue of fully paid Bonus Shares

4. Premium payable on redemption of Redeemable Preference Shares or Debentures

5. Buy-back of own securities (Sec 68)

Auditor verifies:

  • Premium received is credited to Securities Premium A/c ✓
  • Application of SPA is only for the above five permitted purposes ✓

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## 4. Issue at Discount — Section 53, Companies Act 2013

Issue of shares at discount is void (strictly prohibited).

Valid Exceptions:

1. Sweat Equity Shares (Sec 54)

2. Shares issued at discount to creditors when debt is converted into equity under a statutory resolution plan or debt restructuring scheme.

Penalty for violation:

  • Fine: ₹5,00,000 on company and officers
  • Refund all money raised + 12% p.a. interest from the date of issue of shares

Auditor Procedures:

  • Verify no shares were issued at discount during the year.
  • Read minutes of board/general meetings authorising issue.
  • Where debt is converted at discount → verify compliance with RBI guidelines/directions.

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## 5. Sweat Equity Shares — Section 54, Companies Act 2013

Equity shares issued to employees or directors at a discount or for non-cash consideration, for providing know-how or intellectual property / value additions.

Conditions the auditor must verify:

ConditionDetail
AuthorityAuthorised by Special Resolution
Resolution contentSpecifies: number of shares, CMP, consideration, class of directors/employees
Class of sharesSame class as existing equity shares
Listed companyMust comply with SEBI regulations
Unlisted companyMust comply with prescribed rules

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## 6. Reduction of Capital — Section 66, Companies Act 2013

Auditor Procedures:

  • Verify AOA authorises reduction of capital.
  • Verify MOA is suitably altered.
  • Confirm Special Resolution (3/4 majority) was passed — proposal circulated in advance.
  • Vouch Registrar's Certificate regarding reduction of capital.
  • Check accounting entries and revaluation of assets is properly disclosed.
  • Examine Order of Tribunal confirming the reduction.
  • Verify all conditions imposed by Tribunal have been complied with.

Worked example

### Example 1

Sec 52 — Misuse of Securities Premium: A company uses its Securities Premium Account to pay an interim dividend to shareholders. The auditor flags this as a violation — dividend payment is not among the five permitted uses of SPA under Sec 52.

### Example 2

Sweat Equity (Sec 54): XYZ Ltd issues 10,000 equity shares to its CTO at ₹80 (CMP ₹100) as recognition of proprietary software she developed. Auditor verifies: (1) Special Resolution passed at AGM, (2) resolution specifies 10,000 shares, CMP ₹100, consideration as IP rights, class = equity directors, (3) SEBI compliance since XYZ is listed. All conditions met — valid Sweat Equity issue.

### Example 3

Sec 53 Exception — Debt Conversion: ABC Ltd converts ₹50 lakh vendor debt into shares at ₹90 (face value ₹100) under an NCLT-approved restructuring plan. Auditor checks: statutory plan exists, RBI directions followed — this is a valid exception to the Sec 53 prohibition.

### Example 4

Authorised vs. Paid-up Capital: A company increases paid-up capital from ₹50 lakh to ₹1.5 crore against an authorised capital of ₹1 crore. The auditor flags this — paid-up capital cannot exceed authorised capital; MOA must be amended first.

### Example 5

Reduction of Capital (Sec 66): A company cancels ₹10 per share of uncalled capital on partly paid shares. Auditor examines: Tribunal order on file, conditions imposed (e.g., creditor protection) complied with, accounting entries show proper adjustment to capital account.

⚠️ Common exam mistakes

  • Listing only 4 uses of Securities Premium Account — students often omit Buy-back of own securities (5th permitted use under Sec 68).
  • Treating all discount share issues as void — Sweat Equity (Sec 54) and court/RBI-approved debt-to-equity conversions are valid exceptions to Sec 53.
  • Confusing FCGPR (filed with RBI for NRI/FDI) with MCA forms for domestic allotment (PAS-3).
  • Forgetting the full Sec 53 penalty — it is ₹5,00,000 fine PLUS refund of all money with 12% p.a. interest, not just a monetary penalty.
  • In Reduction of Capital, forgetting that BOTH AOA must authorise the reduction AND MOA must be suitably altered — satisfying only one is insufficient.
  • Writing 'ordinary resolution' for Sweat Equity or Reduction of Capital — both require Special Resolution (3/4 majority).
  • Missing audit step of reading BOD/General Meeting minutes when verifying share capital movements.
Bare-Act text Section 53 — Prohibition on Issue of Shares at Discount · Companies Act, 2013 · click to expand
No company shall issue shares at a discount, except as provided in section 54. Any share issued by a company at a discounted price shall be void. Where a company contravenes the provisions of this section, the company shall be punishable with fine which shall not be less than one lakh rupees but which may extend to five lakh rupees and every officer who is in default shall be punishable with imprisonment for a term which may extend to six months or with fine which shall not be less than one lakh rupees but which may extend to five lakh rupees, or with both; and the company shall also be liable to refund all monies received with interest at the rate of twelve per cent per annum from the date of issue of shares.
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