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Imprudent Amendments In GujRERA Form No.3

OTHER / CA. HARDIK JIVRAJBHAI KAKADIYA 28 July 2019

Ref: CAAS/Representations/2019-20/02

Date: 03/06/2019

To,

The Chairman,

Gujarat Real Estate Regulatory Authority,

4th Floor, Sahyog Sankul,

Sector -11,

Gandhinagar – 382010.

 

Respected Sir,

 

Subject: Re: Imprudent Amendments in GujRERA Form No.3

 

Greetings from Chartered Accountants Association, Surat…! As a part of its objectives, Chartered Accountant’s Association, Surat, a non-profit organization, works for the betterment of Chartered Accountancy profession, and various stakeholders of corporate environment. Since Chartered Accountants are the very basic point of inception in the minds of clients at the time of providing value added attestation services to any individual or body corporate, the present representation concerns around the imprudent and impractical amendments brought into immediate and over-night effect by your learned authority, which is expected to create severe negative repercussions in the trade, industry and profession.

 

Our Representation w.r.t. recent amendments and earlier debacles:

1. Frequent Overnight amendments:

RERA is a newly introduced law which is yet to establish its roots in the minds and culture of trade and industry. However it has been regularly noticed that frequent amendments are brought in without adequate consultation with various stakeholders like ICAI, CREDAI, Chamber of Commerce and Industry and Local Builders’ Associations. These frequent amendments are further implemented without giving breathing space to the concerned stakeholders. This is creating an atmosphere of overburdened compliance in a limited time with limited resources on part of builders, especially those builders falling under SME category. Thus, adequate consultation with the stakeholders is desired from now on for any upcoming change in forms/rules/regulations or procedure.

 

2. Lack of Logic in flow of reporting:

Various forms issued under GujRERA lack logical reporting. To explain with example, Form No.3 has to be issued by a Chartered Accountant to the Project Promoter, details whereof are to be accumulated and assimilated from the Project Promoter himself. These detail include the recently added details of KYC like Name, KYC ID and Mobile numbers of the allottees of Project Units.

 

Again in case of Form No.3, in cases where there is non-coherence scenario between information submitted by Architect and Engineer in Form No.1 and Form No.2 respectively, CA has to inform to the Project Promoter, that there is a discrepancy by obtaining reasons for discrepancy/variations from the Project Promoter himself. 

 

All these details have to be provided by none other than Project Promoter.  But, finally the above compiled data has to be reported back to the Project Promoter. Does this kind of data looping activity add to any value addition to the Nation.? Further, this information is required to be certified by a Chartered Accountant. Now the question is whether a person with expert skills in the field of accountancy be required / compelled to certify additional engineering details / raw data, not related to accountancy data. Hence, the logic incorporated in the recently amended forms is dubious, and which should be removed immediately. Any such information related to promoter may directly be required to be furnished under the hands of the Project Promoter.

 

 

3. Certification of Estimated figures:

It has to be acknowledged that under Clause 3 of Part I of Second Schedule to The Chartered Accountants Act, 1949, certifying of estimated/forecasted figures is a professional misconduct, unless the CA clearly indicates the source of information, basis of forecast and major assumptions arriving at the forecast. Yet, Clause 10 of Form No.5 of RERA Audit report, requires the auditor to mechanically certify future contingent project cost without mandating requirements as aforesaid or allowing clarifications as aforesaid. Any such violation created due to static RERA forms should be immediately removed duly amending reporting requirements in line with the long established norms of reporting by ICAI.

 

4. Impatience on “Coherence”:

As per the latest amendment notification amending Form No.3, requires CAs to certify the following:

The physical progress of the project as certified by the architect (Form-1) and engineer (Form-2) seems in coherence with actual expenditure incurred and paid considering project specification:

Yes / No

 

From the above it can be inferred that the certification requirement stresses on the word “Coherence”, between physical progress of project as per Architect’s Certificate and Engineer’s Certificate. Similar point was required to be reported in the Audit Report of CAs in Form No.5 which stated as follows:

11. Whether any discrepancy noticed in forms 1, 2 and 3 with reference to their issuance in accordance with the RERA Act, rules and regulations?

 

Interestingly, the word “Coherence” means? – 

  1. the quality of being logical and consistent.
  2. the quality of forming a unified whole.

But, the legal requirements identified in reporting vide Para 2 above, are itself not logical or consistent with prudent reporting norms. Besides, in cases envisaged by GujRERA, when there may be discrepancy in Physical Progress as reported by Architect and that reported by Engineer, whether a CA has any superior engineering or architectural knowledge commensurate enough to identify and reconcile the discrepancy in Physical Progress.? A Chartered Accountant is a person who is expert in the defined field of Accountancy and Finance. A Chartered Accountant expected to provide various levels of assurances ranging from limited assurance, reasonable assurance to absolute assurance, but only in the fields related to Accountancy and Finance. Any Audit or Certification depends on levels of assurance required/expected by any Government Authority or the Auditee. In this regards, Para 3 of Guidance Note on Reports or Certificates for Special Purposes (Revised 2016) states as follows:

“Sometimes, the applicable law and regulation or a contractual arrangement that an entity might have entered into, prescribe the wording of report or certificates. The wording often requires the use of word or phrase like “certify” or “true and correct” to indicate absolute level of assurance expected to be provided by the practitioner on the subject matter. Absolute assurance indicates that a practitioner has performed procedures as considered appropriate to reduce the engagement risk to zero.”

Here in case of statutory requirements of Form No.3 and Form No.5, the authority requires CAs to “Certify” and give “true and correct” picture, implying a statutory requirement of absolute assurance. Reporting of information by Architects and Engineers is based on estimates (limited assurance is expected), whereas CAs are required to certify facts on basis of those estimated information without sufficient information (absolute assurance is expected). Although requirement of limited assurance may be agreeable, but for that reportable requirements should be rational and judicious, not encroaching the areas of expertise of other professionals or experts.

 

We, as a Chartered Accountants Association, we cannot keep eye on smallest of minute interpretation of an earlier notified statute made by the eccentric lawman. But on account of various issues faced by our members, and brought to our notice, we hereby represent to remove such difficulty. It is also worth noting from the above discussion that when there is a law of land, there cannot be another law, requirements whereof are ultra-vires, directly or indirectly, to the operation of the former. Hence, GujRERA should take necessary steps to suitably amend the following:

  1. requirements of reporting by CAs in Form No.3 in section of “Additional Information for Projects”, for Coherence of Physical Progress which may directly be asked from the Project Promoter along with justification in a suitably designed new form, instead of routing the non-financial information through CA reporting; and
  2. requirements of reporting by CAs in Clause No.11 of Form No.5, of any discrepancy in Form No.1 (Architect) and Form No.2 (Engineer).

Both of the above statutory reporting requirements persisting as on day, pertains to non-financial areas in which CAs do not have requisite expertise or knowledge.  It is to be noted that for CAs hold requisite knowledge only in the field of accountancy and finance and for which they are rigorously trained. However, indirectly requiring a CA Professional to certify non-financial information may lead to initiation of disciplinary actions against them by The Institute Of Chartered Accountants Of India for a misconduct by a CA, falling under the following clauses of Part I of Schedule II to The Chartered Accountants Act, 1949:

  1. Clause 2 - Certifies/submits report without examining the related records
  2. Clause 3 - Permits to use name for vouching the accuracy of future contingent earnings
  3. Clause 7 - Performs professional duties without due diligence/grossly negligent
  4. Clause 8 - Fails to obtain sufficient information for expressing an opinion

 

From the provisions it may be noticed that the reporting of discrepancy or any variation in coherence of non-financial data, cannot be decided on the basis of a mechanical formula, it would require subjective judgment of an Engineer or an Architect. A Chartered Accountant can report any transaction from the books of account, but to ask a CA to provide details of an engineering discrepancy or variation in a categorical manner; is out of the purview of an auditor’s scope of work. Thus it would be desirable that these clauses (additional information in projects) of Form No.3 and (Clause No.10 and 11) Form No.5, may be suitably amended keeping in view the above or this clause may be altogether deleted.

 

5. Urgent need for Clarifications on data to be provided:

As required by recently amended notification No.GujRERA2019/Gen.Reg./Amdt 5, various clarifications are required which are enlisted below:

  1. Words “Date of Agreement of Sale” in Annexure to Form No.3 – “Statement of calculation of receivables from the real estate project” raises following questions:
  2. What If promoter does not enter into Agreement for Sale (Satakhat), but directly executes Sale Deed, whether this column is to be kept blank.
  3. Whether Agreement of Sale is required to be registered or not.
  4. Words “Encumbrance Status” in Annexure to Form No.3 – “Statement of calculation of receivables from the real estate project” raises following questions:
  5. What is meant by Encumbrance.? Does it mean:
  6. “boja” as mentioned with the sub-registrar in name of Project Promoter; or
  7. a Charge registered with Registrar of Companies by the Promoter Company/LLP; or
  8. a “boja” as mentioned with sub-registrar in name of separate Occupant/Customer of the unit; or
  9. a Charge registered by separate Occupant/Customer of the unit; or
  10. an Encumbrance of any other nature not registered for eg. A documented transaction of creating lien on property but not registered, creating right over property in favour of a third party/lender of unsecured loan, or a transaction of “Aajro Maajro”.
  11. Whether such encumbrance to be verified by asking each occupant/customer of the unit or to obtain information from the project promoter;
  12. Which is the authentic source of verification of any encumbrance of “boja”.
  13. Whether reporting is for project wise encumbrance or Unit wise encumbrances.
  14. Whether exercise of verification of such encumbrances have to be undertaken at the stage of each certification eg. Quarterly at the time of issuance of Form No.3.
  15. What if, after an initial verification and identification of any property as without encumbrance, but subsequently the Project Promoter creates encumbrances on whole project without the knowledge of other owners of sold units.

This raises a cardinal question, as whether a Chartered Accountant, who is expert in the field of Accountancy and Finance, can visit and meddle with the field of law, where only advocates have necessary proficiency. As a unified body of Chartered Accountants of Surat, we feel such tasks can only be accomplished by Advocates. For achieving the welfare objective of reporting any encumbrances over any project, so that customers are not cheated, GujRERA should adequately design and device a new form to be reported by legal personnel only, to answer the above cardinal question.

 

6. Multiple use of RERA CA Certificates/Reports:

GujRERA is a new and welcome legislature, which is not only trusted by bankers and customers but even by other government organisations. Documents, Certificates and Reports submitted by Project Promoters are required to be refurnished to various other government/semi-government/private organisations including bankers, financers and even customers. Thus, certifications and reports submitted by CAs assume huge importance. Any loosely issued certificate or report can land CAs in warm waters, not only from RERA but also through various class action suits by other government authorities and organisations. Thus any unwanted information asked and compulsorily endorsed by the CAs either as a part of the overall engagement as audit or as certification, makes that CA a part of the said statement, which if turns out to be a mis-statement or incorrect information, such CAs become susceptible to legal action including allegations of fraud and mis-doings. Such situation can be averted by not compelling CAs to report and/or certify unwanted information not related to their expertise. Even if smallest of unrelated information becomes part of any document intended for a limited assurance required by GujRERA, such information if reported by CAs but from inception wrongly supplied by the Project Promoter, then such information becomes a public document with material misstatement of unrelated information not related to accounts or finance. If other organisations or users of such documents use the same polluted document, allegations may erupt even for an assignment of limited assurance. Such unwanted information include but not limited to details of KYC like Name, KYC ID and Mobile numbers of the allottees of Project Units, should never be asked from CAs, but if required such information should be asked directly from the Project Promoter suitably in a separate form which may be notified by adequate authority of GujRERA.

 

The aforesaid amendments are detrimental to the trade, industry and profession and suitable amendment should be made without further delay. Meticulous detailing of accounting data is also not possible for several RERA registered Project Promoters, as they fall under the SME category and have limited resources. On one side, while the promoters are not able to make their both ends meet due to adverse market conditions, an in-depth RERA compliant accounting requiring building-wise accounting as opposed to a previously envisaged Project wise accounting; which is a true hardship. This is totally against your government’s motto of improving the ranking of India in Ease of Doing Business. 

 

We hope, our representation would have appraised you in light of various hardships faced by the stakeholders, and are also hopeful, that you would do justice to our grievances.

 

Thanks & Regards,

For Chartered Accountants Association, Surat.

 

 

Chairman – Corporate and Allied Laws

 

Copy to: -

1. The Secretary, The Institute of Chartered Accountants of India, (By Email)

ICAI Bhawan, Indraprastha Marg, Post Box No.7100, New Delhi – 110002.

 

 

2. CREDAI (By Email)

F-19, Regent Arcade, Opp. Zaveri & Co., Ghod Dod Road, Surat - 395007.

 

3. South Gujarat Chamber of Commerce, (By Email)

"Samruddhi", 4th Floor, Nanpura, Surat-395001, Gujarat, INDIA.

 

4. Surat Builder’s Association, (By Email)

F-19, Regent Arcade, Opp. Zaveri & Co., Ghod Dod Road, Surat - 395007.

 

Ref: CAAS/Representations/2019-20/02

Date: 03/06/2019

To,

The Chairman,

Gujarat Real Estate Regulatory Authority,

4th Floor, Sahyog Sankul,

Sector -11,

Gandhinagar – 382010.

 

Respected Sir,

 

Subject: Re: Imprudent Amendments in GujRERA Form No.3

 

Greetings from Chartered Accountants Association, Surat…! As a part of its objectives, Chartered Accountant’s Association, Surat, a non-profit organization, works for the betterment of Chartered Accountancy profession, and various stakeholders of corporate environment. Since Chartered Accountants are the very basic point of inception in the minds of clients at the time of providing value added attestation services to any individual or body corporate, the present representation concerns around the imprudent and impractical amendments brought into immediate and over-night effect by your learned authority, which is expected to create severe negative repercussions in the trade, industry and profession.

 

Our Representation w.r.t. recent amendments and earlier debacles:

1. Frequent Overnight amendments:

RERA is a newly introduced law which is yet to establish its roots in the minds and culture of trade and industry. However it has been regularly noticed that frequent amendments are brought in without adequate consultation with various stakeholders like ICAI, CREDAI, Chamber of Commerce and Industry and Local Builders’ Associations. These frequent amendments are further implemented without giving breathing space to the concerned stakeholders. This is creating an atmosphere of overburdened compliance in a limited time with limited resources on part of builders, especially those builders falling under SME category. Thus, adequate consultation with the stakeholders is desired from now on for any upcoming change in forms/rules/regulations or procedure.

 

2. Lack of Logic in flow of reporting:

Various forms issued under GujRERA lack logical reporting. To explain with example, Form No.3 has to be issued by a Chartered Accountant to the Project Promoter, details whereof are to be accumulated and assimilated from the Project Promoter himself. These detail include the recently added details of KYC like Name, KYC ID and Mobile numbers of the allottees of Project Units.

 

Again in case of Form No.3, in cases where there is non-coherence scenario between information submitted by Architect and Engineer in Form No.1 and Form No.2 respectively, CA has to inform to the Project Promoter, that there is a discrepancy by obtaining reasons for discrepancy/variations from the Project Promoter himself. 

 

All these details have to be provided by none other than Project Promoter.  But, finally the above compiled data has to be reported back to the Project Promoter. Does this kind of data looping activity add to any value addition to the Nation.? Further, this information is required to be certified by a Chartered Accountant. Now the question is whether a person with expert skills in the field of accountancy be required / compelled to certify additional engineering details / raw data, not related to accountancy data. Hence, the logic incorporated in the recently amended forms is dubious, and which should be removed immediately. Any such information related to promoter may directly be required to be furnished under the hands of the Project Promoter.

 

 

3. Certification of Estimated figures:

It has to be acknowledged that under Clause 3 of Part I of Second Schedule to The Chartered Accountants Act, 1949, certifying of estimated/forecasted figures is a professional misconduct, unless the CA clearly indicates the source of information, basis of forecast and major assumptions arriving at the forecast. Yet, Clause 10 of Form No.5 of RERA Audit report, requires the auditor to mechanically certify future contingent project cost without mandating requirements as aforesaid or allowing clarifications as aforesaid. Any such violation created due to static RERA forms should be immediately removed duly amending reporting requirements in line with the long established norms of reporting by ICAI.

 

4. Impatience on “Coherence”:

As per the latest amendment notification amending Form No.3, requires CAs to certify the following:

The physical progress of the project as certified by the architect (Form-1) and engineer (Form-2) seems in coherence with actual expenditure incurred and paid considering project specification:

Yes / No

 

From the above it can be inferred that the certification requirement stresses on the word “Coherence”, between physical progress of project as per Architect’s Certificate and Engineer’s Certificate. Similar point was required to be reported in the Audit Report of CAs in Form No.5 which stated as follows:

11. Whether any discrepancy noticed in forms 1, 2 and 3 with reference to their issuance in accordance with the RERA Act, rules and regulations?

 

Interestingly, the word “Coherence” means? – 

  1. the quality of being logical and consistent.
  2. the quality of forming a unified whole.

But, the legal requirements identified in reporting vide Para 2 above, are itself not logical or consistent with prudent reporting norms. Besides, in cases envisaged by GujRERA, when there may be discrepancy in Physical Progress as reported by Architect and that reported by Engineer, whether a CA has any superior engineering or architectural knowledge commensurate enough to identify and reconcile the discrepancy in Physical Progress.? A Chartered Accountant is a person who is expert in the defined field of Accountancy and Finance. A Chartered Accountant expected to provide various levels of assurances ranging from limited assurance, reasonable assurance to absolute assurance, but only in the fields related to Accountancy and Finance. Any Audit or Certification depends on levels of assurance required/expected by any Government Authority or the Auditee. In this regards, Para 3 of Guidance Note on Reports or Certificates for Special Purposes (Revised 2016) states as follows:

“Sometimes, the applicable law and regulation or a contractual arrangement that an entity might have entered into, prescribe the wording of report or certificates. The wording often requires the use of word or phrase like “certify” or “true and correct” to indicate absolute level of assurance expected to be provided by the practitioner on the subject matter. Absolute assurance indicates that a practitioner has performed procedures as considered appropriate to reduce the engagement risk to zero.”

Here in case of statutory requirements of Form No.3 and Form No.5, the authority requires CAs to “Certify” and give “true and correct” picture, implying a statutory requirement of absolute assurance. Reporting of information by Architects and Engineers is based on estimates (limited assurance is expected), whereas CAs are required to certify facts on basis of those estimated information without sufficient information (absolute assurance is expected). Although requirement of limited assurance may be agreeable, but for that reportable requirements should be rational and judicious, not encroaching the areas of expertise of other professionals or experts.

 

We, as a Chartered Accountants Association, we cannot keep eye on smallest of minute interpretation of an earlier notified statute made by the eccentric lawman. But on account of various issues faced by our members, and brought to our notice, we hereby represent to remove such difficulty. It is also worth noting from the above discussion that when there is a law of land, there cannot be another law, requirements whereof are ultra-vires, directly or indirectly, to the operation of the former. Hence, GujRERA should take necessary steps to suitably amend the following:

  1. requirements of reporting by CAs in Form No.3 in section of “Additional Information for Projects”, for Coherence of Physical Progress which may directly be asked from the Project Promoter along with justification in a suitably designed new form, instead of routing the non-financial information through CA reporting; and
  2. requirements of reporting by CAs in Clause No.11 of Form No.5, of any discrepancy in Form No.1 (Architect) and Form No.2 (Engineer).

Both of the above statutory reporting requirements persisting as on day, pertains to non-financial areas in which CAs do not have requisite expertise or knowledge.  It is to be noted that for CAs hold requisite knowledge only in the field of accountancy and finance and for which they are rigorously trained. However, indirectly requiring a CA Professional to certify non-financial information may lead to initiation of disciplinary actions against them by The Institute Of Chartered Accountants Of India for a misconduct by a CA, falling under the following clauses of Part I of Schedule II to The Chartered Accountants Act, 1949:

  1. Clause 2 - Certifies/submits report without examining the related records
  2. Clause 3 - Permits to use name for vouching the accuracy of future contingent earnings
  3. Clause 7 - Performs professional duties without due diligence/grossly negligent
  4. Clause 8 - Fails to obtain sufficient information for expressing an opinion

 

From the provisions it may be noticed that the reporting of discrepancy or any variation in coherence of non-financial data, cannot be decided on the basis of a mechanical formula, it would require subjective judgment of an Engineer or an Architect. A Chartered Accountant can report any transaction from the books of account, but to ask a CA to provide details of an engineering discrepancy or variation in a categorical manner; is out of the purview of an auditor’s scope of work. Thus it would be desirable that these clauses (additional information in projects) of Form No.3 and (Clause No.10 and 11) Form No.5, may be suitably amended keeping in view the above or this clause may be altogether deleted.

 

5. Urgent need for Clarifications on data to be provided:

As required by recently amended notification No.GujRERA2019/Gen.Reg./Amdt 5, various clarifications are required which are enlisted below:

  1. Words “Date of Agreement of Sale” in Annexure to Form No.3 – “Statement of calculation of receivables from the real estate project” raises following questions:
  2. What If promoter does not enter into Agreement for Sale (Satakhat), but directly executes Sale Deed, whether this column is to be kept blank.
  3. Whether Agreement of Sale is required to be registered or not.
  4. Words “Encumbrance Status” in Annexure to Form No.3 – “Statement of calculation of receivables from the real estate project” raises following questions:
  5. What is meant by Encumbrance.? Does it mean:
  6. “boja” as mentioned with the sub-registrar in name of Project Promoter; or
  7. a Charge registered with Registrar of Companies by the Promoter Company/LLP; or
  8. a “boja” as mentioned with sub-registrar in name of separate Occupant/Customer of the unit; or
  9. a Charge registered by separate Occupant/Customer of the unit; or
  10. an Encumbrance of any other nature not registered for eg. A documented transaction of creating lien on property but not registered, creating right over property in favour of a third party/lender of unsecured loan, or a transaction of “Aajro Maajro”.
  11. Whether such encumbrance to be verified by asking each occupant/customer of the unit or to obtain information from the project promoter;
  12. Which is the authentic source of verification of any encumbrance of “boja”.
  13. Whether reporting is for project wise encumbrance or Unit wise encumbrances.
  14. Whether exercise of verification of such encumbrances have to be undertaken at the stage of each certification eg. Quarterly at the time of issuance of Form No.3.
  15. What if, after an initial verification and identification of any property as without encumbrance, but subsequently the Project Promoter creates encumbrances on whole project without the knowledge of other owners of sold units.

This raises a cardinal question, as whether a Chartered Accountant, who is expert in the field of Accountancy and Finance, can visit and meddle with the field of law, where only advocates have necessary proficiency. As a unified body of Chartered Accountants of Surat, we feel such tasks can only be accomplished by Advocates. For achieving the welfare objective of reporting any encumbrances over any project, so that customers are not cheated, GujRERA should adequately design and device a new form to be reported by legal personnel only, to answer the above cardinal question.

 

6. Multiple use of RERA CA Certificates/Reports:

GujRERA is a new and welcome legislature, which is not only trusted by bankers and customers but even by other government organisations. Documents, Certificates and Reports submitted by Project Promoters are required to be refurnished to various other government/semi-government/private organisations including bankers, financers and even customers. Thus, certifications and reports submitted by CAs assume huge importance. Any loosely issued certificate or report can land CAs in warm waters, not only from RERA but also through various class action suits by other government authorities and organisations. Thus any unwanted information asked and compulsorily endorsed by the CAs either as a part of the overall engagement as audit or as certification, makes that CA a part of the said statement, which if turns out to be a mis-statement or incorrect information, such CAs become susceptible to legal action including allegations of fraud and mis-doings. Such situation can be averted by not compelling CAs to report and/or certify unwanted information not related to their expertise. Even if smallest of unrelated information becomes part of any document intended for a limited assurance required by GujRERA, such information if reported by CAs but from inception wrongly supplied by the Project Promoter, then such information becomes a public document with material misstatement of unrelated information not related to accounts or finance. If other organisations or users of such documents use the same polluted document, allegations may erupt even for an assignment of limited assurance. Such unwanted information include but not limited to details of KYC like Name, KYC ID and Mobile numbers of the allottees of Project Units, should never be asked from CAs, but if required such information should be asked directly from the Project Promoter suitably in a separate form which may be notified by adequate authority of GujRERA.

 

The aforesaid amendments are detrimental to the trade, industry and profession and suitable amendment should be made without further delay. Meticulous detailing of accounting data is also not possible for several RERA registered Project Promoters, as they fall under the SME category and have limited resources. On one side, while the promoters are not able to make their both ends meet due to adverse market conditions, an in-depth RERA compliant accounting requiring building-wise accounting as opposed to a previously envisaged Project wise accounting; which is a true hardship. This is totally against your government’s motto of improving the ranking of India in Ease of Doing Business. 

 

We hope, our representation would have appraised you in light of various hardships faced by the stakeholders, and are also hopeful, that you would do justice to our grievances.

 

Thanks & Regards,

For Chartered Accountants Association, Surat.

 

 

Chairman – Corporate and Allied Laws

 

Copy to: -

1. The Secretary, The Institute of Chartered Accountants of India, (By Email)

ICAI Bhawan, Indraprastha Marg, Post Box No.7100, New Delhi – 110002.

 

 

2. CREDAI (By Email)

F-19, Regent Arcade, Opp. Zaveri & Co., Ghod Dod Road, Surat - 395007.

 

3. South Gujarat Chamber of Commerce, (By Email)

"Samruddhi", 4th Floor, Nanpura, Surat-395001, Gujarat, INDIA.

 

4. Surat Builder’s Association, (By Email)

F-19, Regent Arcade, Opp. Zaveri & Co., Ghod Dod Road, Surat - 395007.

 


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