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Microlesson · 5-min read

Audit of Trusts & Societies

## Audit of Trusts & Societies

### Legal Framework — Three Forms of Charitable Institutions

FormPrimary Governing Law
Public TrustState Public Trust Act; if no State Act, then Indian Trusts Act, 1882
SocietySocieties Registration Act, 1860
Non-profit CompanyCompanies Act, 2013 — Section 8

Additional applicable laws (regardless of form):

  • Income Tax Act, 1961 — tax exemptions on income
  • Foreign Contribution (Regulation) Act, 2010 — where foreign contributions are received

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### Books of Account

Charitable and religious trusts must maintain regular books of account to demonstrate the due discharge of responsibilities. The auditor must report whether the trust has maintained proper books of account, including:

Required Record
Cash Book
Ledger
Journal
Copies/counterfoils of bills (machine-numbered or serially numbered) issued by the trust
Original bills received and receipts for payments made by the trust
Any other book necessary for a true and fair view of affairs

### Financial Statements

Every trust must prepare annual financial statements (Balance Sheet and Income & Expenditure Account). The format is prescribed under the applicable State law.

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### Audit of Trusts — Specific Checks

The auditor must ascertain:

1. Whether accounts are maintained regularly and in accordance with the applicable Act and rules

2. Whether receipts and disbursements are properly shown and donations are applied as per trust objects and specific donor directions

3. Whether cash balance and vouchers in the custody of the manager/trustee agree with the accounts at the date of audit

4. Whether all books, deeds, accounts, vouchers, and documents required were produced before the auditor

5. Whether a register of movable and immovable properties is maintained and changes reported to the regional office

6. Whether maximum and minimum number of trustees is maintained as per the trust deed

7. Whether meetings are held regularly as required by the trust instrument

8. Whether minute books of meeting proceedings are maintained

9. Whether any trustee has an interest in the trust's investments (conflict of interest)

10. Whether any trustee is a debtor or creditor of the trust

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### Audit of Societies — Specific Checks

The auditor must ascertain:

1. Governing legislation: Societies Registration Act, 1860 or applicable State law

2. Objects of the society from MoA/bye-laws (charitable, social, cultural, educational)

3. FCRA registration: Whether obtained for receiving foreign contributions

4. Income Tax registration: Whether registered for tax exemption on income

5. Internal controls: Especially over donations and expenditures related to objects

6. Accounting policies: Appropriateness for donations, grants, and specific grants

7. Reimbursed expenses: How expenses reimbursed by donors are recognised in financial statements

8. Registrar inquiries: Whether any inquiry under applicable law is pending — assess implications for audit opinion

9. Irregular/illegal expenditure: All cases of irregular, illegal, or improper expenditure or failure to recover monies or property of the society

10. Breach of trust: Whether irregular expenditure resulted from breach of trust or misapplication by the governing body

Worked example

### Example 1

A trust deed specifies that the trustee count must be maintained between 5 (minimum) and 11 (maximum). At the time of audit, only 4 trustees are active due to resignations and no replacements. Audit implication: The trust is operating in breach of its governing instrument. The auditor must report this finding. Further, any significant financial transactions or board resolutions passed during this period should be examined for valid quorum — decisions taken without proper quorum may be void.

### Example 2

A society registered under the Societies Registration Act, 1860 receives ₹20 lakhs from a foreign foundation. The society does not hold FCRA registration. Audit finding: Receiving foreign contributions without FCRA registration is a violation of the Foreign Contribution (Regulation) Act, 2010. The auditor should prominently report this non-compliance in the audit report and communicate it to the governing body, as it carries significant legal consequences including cancellation of registration.

⚠️ Common exam mistakes

  • Assuming the Indian Trusts Act, 1882 always governs public trusts — where a State has enacted its own Public Trust Act, the State Act takes precedence over the central Act
  • Overlooking conflict-of-interest checks — failing to verify whether trustees are debtors/creditors of the trust or have personal interest in trust investments is a specific audit requirement
  • Not checking whether meeting minutes exist and are properly maintained — governance documentation (minute books, meeting frequency per trust deed) is a statutory audit requirement for trusts
  • Ignoring FCRA registration verification for societies receiving foreign contributions — this is a legal compliance issue with criminal consequences, not merely an accounting matter
  • Treating all donations as income without verifying the donor's specific directions — a donation directed to form corpus must go to the balance sheet, not the I&E Account
Reference:
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