Additional Disclosure requirements for Companies (including Section 8 Companies) Post Demonetization!

The Ministry of Corporate Affairs
(MCA)
has notified certain
amendments in Schedule III to the Companies Act 2013, applicable with effect
from 30th March 2017,
requiring companies (this includes non-profit
Section 8 Companies) to disclose the details of “Specified Bank Notes” (SBN)
held and transacted during the period 8th November 2016 to 30th
December 2016 (i.e. during the period when currency notes of Rs. 500/- and Rs.
1,000/- were demonetized or rendered as not legal tender).
 
Every company (including
Section 8 Company) shall disclose the details of “Specified Bank Notes” (SBN)
held and transacted during the period from 8th November 2016 to 30th
December 2016. Consequently, the financial statement of all Companies for the financial
year ended 31.03.2017 must compulsorily provide information
as provided in the table
below:
Specified Bank Notes (Rs. 500 & Rs. 1,000)
Other Denomination Notes
Total
Closing cash in hand as on
08.11.2016
(+) Permitted receipts
(-) Permitted payments
(-) Amount deposited in Banks
Closing cash in hand as on
30.12.2016
Further, as per MCA
Notification No. G.S.R. 307(E) dated 30th March, 2017; there is an
amendment in Companies (Audit and Auditors) Rules, 2014.  
In Rule 11 after
clause (c), the following clause has been inserted, namely: “(d) whether the
company had provided requisite disclosures in its financial statements as to
holdings as well as dealings in Specified Bank Notes during the period from 8th
November, 2016 to 30th December, 2016 and if so, whether these are
in accordance with the books of accounts maintained by the company.”.
Rule 11 relates to
matter to be included in ‘Auditor Report’ and as such, it will be binding for
the auditors to bring up this information relating to Specified Bank Notes in
its reports.

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