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Microlesson · 5-min read

CARO 2020 - Cash Losses, Auditor Resignation, Going Concern & CSR (Clauses xvii-xxi)

# CARO 2020 — Clauses (xvii) to (xxi)

## Clause (xvii) — Cash Losses

Whether the company incurred cash losses in the FY and in the immediately preceding FY. If yes — state the amount of cash losses (for both years).

## Clause (xviii) — Resignation of Statutory Auditors

If statutory auditors resigned during the year — whether the incoming auditor has taken into consideration the concerns/issues/objections raised by the outgoing auditor.

## Clause (xix) — Going Concern

Based on:

  • Financial ratios
  • Ageing & expected realisation of financial assets
  • Expected payment dates of financial liabilities
  • Other information & management plans

…whether the auditor is of the opinion that no material uncertainty exists as of the audit report date that the company is capable of meeting liabilities existing at B/S date as and when they fall due within one year of the B/S date.

> This is a factual one-year liquidity assessment — distinct from SA 570's going concern opinion.

## Clause (xx) — Corporate Social Responsibility (CSR)

(a) Other than ongoing projects — Whether unspent CSR has been transferred to Schedule VII Fund within 6 months of FY expiry, per Sec 135.

(b) Ongoing projects — Whether unspent CSR is transferred to a separate account as per Sec 135.

## Clause (xxi) — Consolidated Financial Statements

Whether there are any qualifications or adverse remarks in the CARO reports of companies included in the Consolidated FS. If yes — indicate:

  • Details of the company
  • Para numbers of the CARO report containing the qualifications/adverse remarks

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## Reasons for Unfavourable/Qualified Answers (overall principle)

  • Where any CARO answer is unfavourable or qualified — the auditor's report shall state the basis for such answer.
  • Where the auditor is unable to express an opinion on any matter — the report shall indicate the fact along with reasons why an opinion is not possible.

Worked example

### Example 1

Example — Clause (xvii):

FY 2024-25 cash loss: ₹40 lakhs; FY 2023-24 cash loss: ₹25 lakhs.

Reporting: Yes, cash losses incurred in both years. State both amounts.

If the company had cash profit in FY 2023-24 → only report current year loss.

### Example 2

Example — Clause (xx)(a):

Company's CSR liability FY 2024-25 = ₹2 crore. Spent ₹1.5 crore on non-ongoing projects. Unspent ₹50 lakhs not transferred to Schedule VII Fund by 30-Sep-2025 (within 6 months of 31-Mar-2025).

Reporting: Non-compliance with Section 135 — unspent ₹50 lakhs not transferred within 6 months.

### Example 3

Example — Clause (xxi):

Parent Co. P consolidates Subsidiaries A and B. CARO report of A has a qualification on Clause (vii)(a) — statutory dues. B has no remarks.

Reporting in P's CARO: Yes, qualification exists in CARO of Subsidiary A under Clause (vii)(a) — provide name and para number.

⚠️ Common exam mistakes

  • Under clause (xvii), reporting net accounting loss instead of cash loss — cash loss = loss before depreciation & amortisation
  • Confusing clause (xix) with SA 570 — clause (xix) is a one-year liquidity comment based on ratios/ageing; SA 570 governs the overall going concern opinion
  • Under clause (xx), forgetting that the 6-month transfer deadline applies only to non-ongoing projects; ongoing projects have a separate-account requirement
  • Clause (xxi) requires reporting both details of co. AND para numbers — students often miss the para number
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