Start two calendars when the office becomes vacant
For a company already subject to cost audit, Rule 6(3A) of the Companies (Cost Records and Audit) Rules, 2014 covers a casual vacancy caused by resignation, death or removal. The Board fills it within 30 days of occurrence. The company then informs the Central Government in CRA-2 within 30 days of the replacement appointment. Record both actual event dates; appointment and filing are separate obligations. The original annual appointment procedure in Rule 6(1)–(2) is a different workflow. Checked on 5 November 2026.
Read the applicable text: Institute of Cost Accountants: Rule 6(1A), (3) and (3A) MCA Gazette notification G.S.R. 361(E): substituted CRA-2 Institute official cost-audit rules and amendments page.
Establish the effective vacancy before counting
Retain the resignation and its operative facts, evidence of death, or the effective removal decision as relevant. A date on which the company later gathers paperwork is not automatically the occurrence date. In a removal before expiry of term, Rule 6(3) requires a Board resolution after a reasonable opportunity to be heard and reasons recorded in writing. Retain the hearing record, reasons and resolution. A disputed effective date needs legal review rather than a convenient date chosen to make a filing appear timely.
Make a valid replacement decision
Before appointing the replacement, verify eligibility under section 148 and obtain written consent and eligibility evidence. Use the Rule 6(1A) checklist to cover disqualifications, applicable section 141 criteria, appointment limits and disclosed proceedings. Preserve the Board resolution, scope, financial year and handover instructions. Do not treat an email naming a candidate, an internal recommendation or a form draft as the Board appointment. Determine applicability and existing audit scope from the prior file; this article assumes Rule 3 and Rule 4 coverage rather than recalculating turnover thresholds.
Use the vacancy route in the substituted CRA-2
MCA notification G.S.R. 361(E), dated 30 May 2025, substitutes CRA-2 effective 14 July 2025. The published form’s nature-of-intimation field 1(f) offers option D for a casual vacancy. Reconcile the original CRA-2 or Form 23C SRN for the current financial year, the number and particulars of the outgoing auditors, each effective vacancy date and reason, and the replacement auditor and Board meeting details. Retain the scope in the appointment file; the published form excludes the separate product and service particulars section for option D. Use the current applicable filing kit and retain the resolution attachment, signed submission and acknowledgement. The notice concerns appointment; it is not the cost audit report filed through CRA-4.
Keep both timeliness conclusions visible
A timely form cannot cure a late Board appointment. A timely Board decision cannot cure late intimation. Calculate each period from its own trigger, record actual completion and preserve evidence of any separate relief rather than assuming it. The examples use calendar-day baselines with the trigger day excluded, no holiday adjustment and stipulated effective event dates. They do not calculate additional fees or determine any adjudication consequence. Escalate deadline conflicts before filing rather than altering event dates to pass a portal check.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Early replacement after resignation
Effective vacancy 1 June 2026 gives baseline 1 July for the Board. Appointment 20 June gives CRA-2 baseline 20 July. The first deadline does not govern the second once appointment occurs.
Illustrative example 2: Death and September appointment
Vacancy 15 August 2026 gives baseline 14 September. Board appointment 10 September leaves four days of appointment margin and starts a separate 30-day period ending 10 October.
Illustrative example 3: Timely appointment, late intimation
Vacancy 1 October 2026 and appointment 25 October imply Board baseline 31 October and CRA-2 baseline 24 November. A 26 November filing is two calendar days after the form baseline, although appointment itself is timely.
Illustrative example 4: Late appointment, prompt form
Vacancy 1 June 2026; Board appoints on 3 July, two days beyond 1 July. The separate form baseline is 2 August. A 10 July filing is 23 days before that endpoint; it does not erase the Board delay.
Illustrative example 5: Removal clock starts on effective decision
Assume removal takes effect on 12 September 2026 after the requisite process. The Board replacement baseline is 12 October. Appointment on 30 September starts the form period ending 30 October, even if hearing correspondence began earlier.
Illustrative example 6: Year boundary
Vacancy 20 December 2026 gives Board baseline 19 January 2027. Appointment on 10 January gives CRA-2 baseline 9 February 2027. Keep the audit’s financial-year scope from the appointment record; the calendar-year change does not reset either clock.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Confirm existing audit obligation | Retain current Rule 3/4 conclusion and prior appointment record. |
| 2 | Identify vacancy cause | Document resignation, death or effective removal. |
| 3 | Fix the effective date | Distinguish occurrence from the later paperwork date. |
| 4 | Calendar the first clock | Record the Board replacement baseline and internal target. |
| 5 | Verify removal procedure if relevant | Keep hearing evidence, written reasons and resolution. |
| 6 | Obtain consent and certificate | Review eligibility before Board appointment. |
| 7 | Record replacement scope and date | Preserve the signed Board resolution and communication. |
| 8 | Calculate the second clock | Use actual appointment date for the CRA-2 baseline. |
| 9 | Complete vacancy-specific particulars | Tie option, prior SRN, outgoing details and replacement details to evidence. |
| 10 | Verify filing evidence | Retain acknowledgement and document both timeliness conclusions. |
Sixteen practitioner FAQs
1. Which vacancies does Rule 6(3A) address?
Death, resignation and removal of the cost auditor.
2. Who fills the vacancy?
The Board of Directors.
3. What starts the first 30 days?
Occurrence of the vacancy.
4. What starts the second 30 days?
Actual appointment of the replacement.
5. Can the same date be used for both?
Only if occurrence and appointment actually coincide.
6. Does a form filed on time cure late appointment?
No. The two obligations are separate.
7. Is a draft nomination an appointment?
No. Retain the Board’s actual decision.
8. What is required before premature removal?
Reasonable hearing opportunity, written reasons and Board resolution under Rule 6(3).
9. What if the resignation date is disputed?
Resolve the operative date from evidence and legal analysis before finalising the calendar.
10. Which form reports the new appointment?
CRA-2.
11. Which vacancy option is in the substituted form?
Option D in nature-of-intimation field 1(f).
12. When did the 2025 form amendment take effect?
14 July 2025.
13. Why preserve the original SRN?
The vacancy route links back to the earlier current-year appointment filing.
14. Is CRA-4 the replacement notice?
No. CRA-4 relates to the report, while CRA-2 concerns appointment intimation.
15. Do statutory financial auditor vacancy rules replace Rule 6(3A)?
No. Cost audit has its own appointment and reporting framework.
16. Can I assume a holiday or extension changes the date?
No. Verify applicable relief separately and plan to file early.
Official sources
Institute of Cost Accountants: Rule 6(1A), (3) and (3A) MCA Gazette notification G.S.R. 361(E): substituted CRA-2 Institute official cost-audit rules and amendments page