Supplementary comments have their own statutory route
Companies Act section 143(6) gives the CAG a right, within sixty days from receipt of the subsection (5) audit report, to conduct supplementary audit and comment upon or supplement the report. Comments or supplements must be sent to the persons entitled to audited financial statements under section 136(1) and placed before the AGM at the same time and in the same manner as the audit report. An internal management-response file is not a substitute for that circulation.
Read the applicable text: Official Companies Act text: section 143(5)–(7) CAG: financial attest audit mandate.
Start with the correct report and receipt
Identify the government-company audit under subsection (5), the statutory auditor’s report, its version and actual delivery to the CAG. The report date and management’s dispatch date are evidence items, but neither automatically proves CAG receipt. Maintain acknowledgement and delivery history. The relative-day examples below are control arithmetic, not a legal ruling on excluding days, holidays or any disputed actual receipt date.
Keep statutory and supplementary work distinct
The statutory auditor remains responsible for the statutory opinion. The CAG’s supplementary audit can require information or additional information through authorised persons as directed. Retain the requests, authority, supporting schedules and responses. Do not describe supplementary work as a second company-appointed statutory auditor or confuse it with the separate test-audit power under section 143(7).
Control comments by version and recipient
Maintain the issued CAG comments or supplement, response drafts and final transmission evidence separately. Reconcile comments to the precise accounts and audit report. A management explanation does not erase an issued comment; any subsequent official communication must be preserved and its effect established. Do not silently edit CAG wording to match the company’s preferred narrative.
Reconcile circulation and AGM presentation
Use the actual section 136(1) entitled-recipient population, including persons entitled beyond a casual shareholder mailing list. Record dispatch channels and exceptions and ensure the comments accompany the relevant audit-report presentation at the AGM. This article does not invent an independent ROC form, a fresh appointment requirement or an automatic deadline extension for other company obligations.
Escalate discrepancies before finalising the pack
A missing acknowledgement, incomplete comment attachment or mismatched report version needs an identified owner and documented resolution. Passage of a spreadsheet’s sixty-day counter is not by itself proof of a favourable audit outcome or general legal clearance. Consider actual correspondence and the full applicable framework before finalising statements or meetings. This use case is distinct from CAG first-auditor appointments and casual vacancies.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Receipt versus report date
The audit report is signed on relative day 0 and verified CAG receipt occurs on day 8. At day 38, thirty days have elapsed since receipt and thirty remain in a simple sixty-day control. Measuring from signature would incorrectly show thirty-eight elapsed; actual legal day counting needs review.
Illustrative example 2: Receipt-based monitoring
With verified receipt as relative day 0, a review after forty-five elapsed days leaves fifteen days in the sixty-day monitoring window. This arithmetic is not a finding that comments must or must not be issued in a specific case.
Illustrative example 3: Recipient completeness
An established section 136(1) population contains 250 entitled recipients. Transmission evidence covers 240, leaving ten exceptions to resolve. The ten are not made compliant by recording the pack as dispatched to most members.
Illustrative example 4: Attachment failures
Of 120 electronic transmissions, eight failed. Confirmed successful sends are 112. Reconcile the eight individually, including whether the CAG attachment accompanied the audit report, rather than simply counting generated emails.
Illustrative example 5: Version reconciliation
A final issued comment pack has six pages, while the draft AGM attachment has four. Two pages are missing from that attachment. Page-count agreement is only one control; compare actual content and version identifiers.
Illustrative example 6: Separate financial impacts
Assume two issued observations refer to unrelated balances of ₹12 lakh and ₹8 lakh. Their referenced population totals ₹20 lakh, but that is not automatically a ₹20 lakh adjustment or loss. Any accounting correction requires analysis of each observation and the applicable standards.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify statutory scope | Actual government-company audit and subsection (5) report. |
| 2 | Identify report version | Signed statutory report and accounts identifiers. |
| 3 | Prove CAG receipt | Acknowledgement and delivery evidence. |
| 4 | Track the sixty-day reference | Receipt-based control with legal counting review. |
| 5 | Retain supplementary requests | Authorised information requests and responses. |
| 6 | Separate draft and issued comments | Official version and communication history. |
| 7 | Build entitled-recipient population | Section 136(1) evidence. |
| 8 | Reconcile dispatch completeness | Comments, audit report and exception resolution. |
| 9 | Match AGM materials | Same-time and same-manner presentation evidence. |
| 10 | Archive final cross-references | Accounts, reports, comments, responses and minutes. |
Sixteen practitioner FAQs
1. Does the sixty-day reference start at the auditor’s signature?
The provision uses receipt by the CAG of the subsection (5) report.
2. Is dispatch alone proof of receipt?
Not necessarily. Obtain actual delivery evidence.
3. Is supplementary audit another statutory appointment?
No. Keep the two roles distinct.
4. May additional information be required?
Yes, through the supplementary-audit authority described in subsection (6).
5. Are comments only for management?
No. The statutory circulation and AGM requirements apply.
6. Who receives the comments?
Persons entitled to audited financial statements under section 136(1).
7. Is a shareholder-only list always sufficient?
No. Establish the full entitled population.
8. Can the company rewrite an issued comment?
Do not silently alter the official text.
9. Does a response automatically cancel a comment?
No. Establish the effect of actual official communications.
10. When are comments placed at the AGM?
At the same time and in the same manner as the audit report.
11. Are failed emails completed circulation?
Not merely because they were generated or sent unsuccessfully.
12. Does an observation amount equal an accounting adjustment?
Not automatically. Analyse the issue and applicable standard.
13. Is the test-audit power identical?
No. Section 143(7) is separately framed.
14. Does expiry of the spreadsheet counter mean clean clearance?
No. That conclusion cannot be inferred from arithmetic alone.
15. Does this article prescribe a ROC filing form?
No. Review applicable filing obligations separately.
16. Why retain final versions together?
To establish which accounts and statutory report the comments concern.
Official sources
Official Companies Act text: section 143(5)–(7) CAG: financial attest audit mandate