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Microlesson · 5-min read

CARO 2020 – Clauses (i) & (ii): PPE, Intangible Assets, and Inventory

## CARO 2020 – Clause (i): Property, Plant & Equipment and Intangible Assets

### Five Reporting Areas

1. Quantitative Records

Whether the company maintains proper records showing quantitative details of PPE and intangible assets.

2. Physical Verification

  • Whether physical verification was conducted at regular intervals
  • If discrepancies were noticed — whether they have been dealt with in the books of accounts

3. Title Deeds of Immovable Property

Whether title deeds are held in the name of the company. If NOT, the report must disclose:

  • Description of the property
  • Gross carrying value
  • Whether held in the name of a promoter, director, their relative, or employee
  • Period for which held (with range, if appropriate)
  • Reasons for not being in the company's name

4. Revaluation

If the company revalued PPE or intangible assets:

  • Was the revaluation based on valuation by a registered valuer?
  • If the change due to revaluation ≥ 10% of net carrying value → report the amount

5. Benami Property

Whether any proceedings are initiated or pending against the company under the Benami Transactions (Prohibition) Act, 1988 — and whether the same is disclosed in the financial statements.

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## CARO 2020 – Clause (ii): Inventory

### Physical Verification

  • Whether physical verification was conducted by management at reasonable intervals
  • If discrepancy of ≥ 10% in aggregate for any particular item → whether the discrepancy has been dealt with in the books

### Working Capital Limits

If the company has sanctioned working capital limits > ₹5 crore in aggregate from banks or financial institutions:

  • Whether quarterly returns/statements were filed with the lenders
  • Whether those returns are in agreement with the books of accounts

Worked example

### Example 1

Example 1 – Title deed not in company's name

Infra Build Ltd has a warehouse. The title deed is in the name of the Managing Director's wife (a relative of a director). The warehouse was gifted to the company 3 years ago but paperwork was never updated.

What should the CARO report state?

Answer: The auditor must report under Clause (i) that the title deed of immovable property (the warehouse) is not in the name of the company. The report must include: description of property, gross carrying value, that it is held in the name of a director's relative, period held (approximately 3 years), and the reason for non-registration in the company's name.

### Example 2

Example 2 – Revaluation threshold

ABC Mfg Ltd revalued its plant. Net carrying value before revaluation: ₹40 crore. Revalued amount: ₹45 crore (increase of ₹5 crore = 12.5%).

Must the auditor report this?

Answer: Yes. Since the change due to revaluation (12.5%) is ≥ 10% of the net carrying value, the auditor must report this revaluation amount under Clause (i). The auditor must also verify that the revaluation was done by a registered valuer.

### Example 3

Example 3 – Working capital limit and quarterly statements

Retail Co Ltd has a working capital loan of ₹6 crore from SBI. During the year, it filed quarterly stock statements with SBI. The December quarter statement showed inventory of ₹4 crore but the books reflected ₹3 crore.

What must the auditor report?

Answer: Since working capital limit > ₹5 crore, the auditor must verify quarterly returns. The auditor must report under Clause (ii) that the quarterly returns filed with the bank are not in agreement with the books of accounts (inventory discrepancy of ₹1 crore in the December quarter statement).

⚠️ Common exam mistakes

  • Forgetting that the 10% threshold for inventory discrepancy is 'in aggregate for a particular item' — not overall inventory discrepancy.
  • Reporting revaluation for any change in value — the threshold is ≥ 10% of net carrying value before revaluation.
  • Overlooking the working capital limit test — students often miss that the ₹5 crore threshold triggers the quarterly statement verification obligation.
  • Confusing 'regular intervals' (PPE physical verification) with 'reasonable intervals' (inventory physical verification) — both terms are used but for different assets.
  • Not reporting benami property proceedings if they exist but are undisclosed in FS — the auditor must specifically check for this and report.
Reference: Clauses (i) and (ii) of CARO 2020 — Companies (Auditor's Report) Order, 2020
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