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Microlesson · 5-min read

Audit of Non-Governmental Organisations (NGOs)

## Audit of Non-Governmental Organisations (NGOs)

### What is an NGO?

NGOs are non-profit organisations that raise funds from members, donors, or contributors to achieve social objectives — education, medical facilities, economic assistance to the poor, disaster management, etc.

### Legal Forms of NGOs in India

FormGoverning Law
SocietySocieties Registration Act, 1860
TrustIndian Trusts Act, 1882
Non-profit CompanyCompanies Act, 2013 — Section 8

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### Sources and Application of Funds

#### Sources of Funds

Grants and donations, fund-raising programmes, membership fees, subscriptions, technical assistance fees, sale of produce or publications, advertisements.

#### Key Concepts in Fund Classification

Fund TypeDescriptionAccounting Treatment
Corpus ContributionPromoter-type contribution forming the capital of the NGO; with donor's specific direction to form part of corpusCapital receipt — shown as liability in Balance Sheet, NOT as income
Revolving FundRotated as temporary loans to other NGOs/beneficiariesInterest earned may go back to the fund or to I&E Account per fund rules
Grant for Fixed AssetsSpecifically for purchasing/constructing assetsApplied to acquire the specified asset
Contributions in KindAssets such as land, buildings, vehicles, food, books, raw materialsValued and recorded appropriately

S. 11(1)(d), Income Tax Act, 1961: Voluntary contributions directed to form part of the corpus are excluded from total income — no tax liability on such receipts.

#### Application of Funds

Establishment costs, administrative/office expenses, maintenance expenses, programme/project expenses, donations and contributions given.

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### Audit Planning — Key Considerations

The auditor should:

1. Understand the NGO's mission, vision, areas of operations, and operating environment

2. Update knowledge of relevant statutes: FCRA 2010, Societies Registration Act 1860, Income Tax Act 1961 (amendments, circulars, judicial decisions)

3. Review the legal form, MoA, AoA, Rules & Regulations

4. Review Organisation chart, Financial & Administrative Manuals, Programme/Project Guidelines, Funding Agency requirements, budgetary policies

5. Examine minutes of Board/Managing Committee/Governing Body for financial impact of decisions

6. Study accounting system, procedures, internal controls and internal checks

7. Set materiality levels

8. Determine nature and timing of reports

9. Consider involvement of experts and their reports

10. Review the previous year's audit report

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### Audit Programme — Area-wise Procedures

ItemAudit Procedure
Corpus FundVouch contributions/grants with donor letters confirming corpus direction; verify interest income with Investment Register and physical investments
ReservesVouch transfers from projects with donor letters and board resolutions; check capital reserve adjustments
Ear-marked FundsCheck donor requirements, board resolutions, scheme rules
Project/Agency BalancesVouch disbursements per donor agreements for each balance
LoansVouch with loan agreements and counterfoils of receipts issued
Fixed AssetsVouch acquisitions/disposals, depreciation, authorisations, donor letters; verify title for immovable property
InvestmentsVerify Investment Register and physical investments; confirm in NGO's name; check approvals for purchases/sales and bank entries for principal and interest
Cash in HandPhysical verification at year end; agree to books
Bank BalanceCheck bank reconciliation; investigate old/unadjusted items
InventoryVerify quantities; obtain management certificate for quantities and valuation
Programme & Project ExpensesVerify donor agreement conditions; check TDS deduction, deposit, and return filing for contract-based programmes
Establishment ExpensesVerify PF, LIC premium, ESI deductions deposited within prescribed time; check administrative expenses

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### Checking Income Receipts

Income TypeAudit Procedure
Contributions & GrantsCheck donor agreements and grant letters; verify foreign contributions deposited in the designated FCRA bank account
Fund-raising ProgrammesVerify internal controls; identify persons responsible for collection; ensure collections are counted and deposited in bank daily
Membership FeesCross-check with Membership Register; distinguish entrance fees, annual fees, and life membership fees
SubscriptionsReconcile with subscription register, receipts issued, and dispatch of magazines/circulars; verify against subscription rate schedule
Interest & DividendsCross-check with investments held during the year

FCRA 2010 Compliance: Financial statements in the prescribed format must be furnished to the Ministry of Home Affairs within 60 days from the close of the financial year (i.e., by 30 May each year).

Worked example

### Example 1

An NGO receives ₹50 lakhs from a foreign donor with a letter specifying it is a 'corpus contribution'. Audit procedure: (1) Vouch the receipt against the donor letter confirming the corpus direction. (2) Verify it is recorded as a capital receipt/liability in the Balance Sheet — NOT as income in the I&E Account. (3) Confirm the foreign contribution was deposited in the designated FCRA bank account. (4) Verify this amount is excluded from taxable income under Section 11(1)(d) of the Income Tax Act, 1961.

### Example 2

An NGO's programme expense account shows ₹30 lakhs paid to contractors for a rural livelihood project. Audit procedure: (1) Check the donor agreement to confirm the programme is within sanctioned scope and budget. (2) Verify TDS was deducted on contractor payments at the applicable rate, deposited on time, and TDS returns filed. (3) Cross-check expenses against the project-wise ledger and donor utilisation certificate. (4) Obtain and verify supporting vouchers for each payment.

⚠️ Common exam mistakes

  • Treating all donations as income in the I&E Account — corpus contributions and capital grants are balance sheet items (liabilities or capital funds), not I&E income
  • Forgetting FCRA compliance — foreign contributions must be deposited in the designated FCRA bank account, and statements must be reported to the Ministry of Home Affairs within 60 days of year-end
  • Not verifying TDS compliance for programme/project expenses involving contractors — this is a common statutory lapse in NGOs and creates tax liability plus interest/penalties
  • Ignoring the accounting treatment of revolving fund interest — it may go back to the fund OR to the I&E Account depending on fund rules; verify the policy and its consistent application
  • Overlooking in-kind contributions (land, food, equipment, raw materials) — these must be valued and recorded; omission understates both assets and capital/income
Bare-Act text Section 11(1)(d) · Income Tax Act, 1961 · click to expand
income in the form of voluntary contributions made with a specific direction that they shall form part of the corpus of the trust or institution shall not be included in the computation of total income
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