Start the company’s filing clock from evidenced receipt
For companies required to obtain cost audit under section 148 and the applicable rules, rule 6(6) ordinarily requires CRA-4 within thirty days of receipt of a copy of the cost-audit report, with full information and explanation on every reservation or qualification. It requires XBRL filing. The cost auditor’s separate rule 6(5) duty is to forward the duly signed report to the Board within 180 days of financial-year closure. Report signing, forwarding, company receipt and filing are distinct events. This article addresses the report handoff, not the turnover applicability or appointment exercise.
Read the applicable text: ICMAI statutory rule text: rule 6, read with later amendments ICMAI current cost-records and audit resources MCA 3 December 2018 amendment notification, reproduced by CAIRR MCA G.S.R. 361(E), actual Gazette notification reproduced by CAIRR.
Preserve the Board’s two different functions
Rule 6(3B) requires Board approval of the cost statements and other statements to be annexed before they are signed on its behalf and submitted to the cost auditor. Rule 6(5) then requires the Board to consider and examine the auditor’s report, particularly reservations or qualifications. A pre-audit annexure approval does not prove later consideration of the completed report. Keep the resolutions, signed statements, final report and company responses in sequence.
Use the notified form applicable to the filing
G.S.R. 361(E), dated 30 May 2025 and effective 14 July 2025, substituted CRA-4. In that notified form, item 1(e) asks for the appointment-form SRN; item 2 covers financial-year details and the Board meeting approving the annexure; item 3 records AGM-extension information; items 4 and 5 distinguish covered and uncovered industries/sectors/products/services; item 6 contains auditor details, including report receipt date at 6(m). Item 7 deals with report qualifications, reservations, adverse remarks and observations/suggestions. Match the actual form and current filing instructions when executing the submission.
Apply the AGM-extension proviso carefully
The rule 6(6) proviso inserted by G.S.R. 1157(E), dated 3 December 2018, permits companies granted extension of AGM time under section 96(1) to file CRA-4 within the resultant extended financial-statement filing period under section 137. A pending application or an internal postponement is not the grant specified in that proviso. Retain the grant, actual relevant dates and the resulting computation. The ordinary thirty-day illustrations below assume no such extension and no separately applicable relaxation; old circulars for earlier financial years are not standing annual extensions.
Build a complete report-to-XBRL reconciliation
Use one controlled report version and reconcile reporting period, units, product/service coverage, auditor identity and financial totals to the converted XBRL document. For every reservation or qualification, retain the exact report wording and a specific company explanation backed by evidence. Do not silently rewrite the signed auditor’s conclusion to remove a mismatch. Distinguish an auditor’s observation from the company’s response and preserve both.
Retain completion evidence
The notified declaration confirms that the XBRL documents convert the duly signed report and the company’s required information and explanations. Technical validation alone cannot establish faithful conversion or compliance with the receipt clock. Keep the submitted form, XBRL, signed source report, explanations, authorisation, fee evidence and acknowledgement. If a report arrives late or has deficiencies, escalate and establish the actual legal position; changing the recorded receipt date is not a cure.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Signing date is not automatically receipt date
A report is signed on 10 September 2026 and actually received by the company on 14 September. Under the ordinary receipt-based clock, thirty elapsed days after receipt gives 14 October 2026, excluding the receipt day. Using signing plus thirty days would produce 10 October, four days earlier. Keep both dates and evidence of the actual handoff; separately assess the auditor’s forwarding obligation.
Illustrative example 2: An early report creates an early ordinary filing date
A signed report is received on 1 August 2026. The ordinary thirty-day date is 31 August 2026. A company planning only around an assumed September reporting season would overlook an earlier triggered clock. No AGM-extension proviso or other relaxation is assumed.
Illustrative example 3: Internal processing does not restart receipt
The company receives the report on 22 September 2026; the finance team circulates it internally on 26 September. Thirty days after actual receipt gives 22 October, not 26 October. The four-day internal routing delay does not create four extra statutory days. Evidence the first receipt by the company rather than the convenience of a later internal log.
Illustrative example 4: Reconcile multiple report receipts without assuming the latest controls
For one company, auditor A’s report is received on 5 September and auditor B’s on 12 September 2026. The ordinary thirty-day dates are 5 October and 12 October, seven days apart. Track both receipts and organise the company filing to comply with the applicable obligations; do not assume that B’s later report restarts A’s clock or that two reports necessarily require two separate CRA-4 filings.
Illustrative example 5: Explain a quantified reservation
The signed report identifies ₹18 lakh unsupported allocation and ₹7 lakh unreconciled utilities, a combined ₹25 lakh issue register. Company evidence resolves ₹11 lakh of the allocation and ₹4 lakh of utilities, totalling ₹15 lakh. The unresolved working is ₹7 lakh plus ₹3 lakh, or ₹10 lakh. The company’s explanation must preserve the report and identify this reconciliation rather than replacing the auditor’s ₹25 lakh statement with an unexplained ₹10 lakh figure.
Illustrative example 6: Reconcile file coverage
The company’s verified universe contains 14 reportable product/service categories for this example: 11 covered by the cost report and three not covered. A draft XBRL mapping lists only ten covered categories and three uncovered, or 13 in total. One covered category is missing. Reconcile its identity and treatment before submission; numerical agreement alone would still not establish correct tariff or category mapping.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Confirm this is a cost-audit company | Section 148 and current applicability analysis. |
| 2 | Identify the reporting period | Appointment SRN, final year dates and report scope. |
| 3 | Verify annexure approval | Rule 6(3B) Board approval and signed statements. |
| 4 | Record report receipt | Signed report and contemporaneous delivery evidence. |
| 5 | Separate the auditor’s clock | Rule 6(5) forwarding chronology. |
| 6 | Calculate the company’s filing date | Receipt plus ordinary period and any supported exception. |
| 7 | Check any AGM-extension reliance | Granted order, item 3 evidence and rule 6(6) proviso working. |
| 8 | Reconcile coverage and amounts | Items 4–6, product/service schedule and XBRL cross-check. |
| 9 | Approve specific explanations | Board consideration and reservation-by-reservation evidence. |
| 10 | Archive actual submission | Authorisation, signed source, submitted XBRL, form and acknowledgement. |
Sixteen practitioner FAQs
1. Is CRA-4 the appointment intimation?
No. CRA-2 and CRA-4 serve different appointment and report-filing purposes.
2. Does signing always prove company receipt?
No. Preserve the actual receipt evidence and distinguish the events.
3. Does finance-team circulation restart the clock?
No. Internal circulation is not a fresh statutory receipt event.
4. Is the auditor’s 180-day duty the same as the company’s filing period?
No. Rule 6(5) forwarding and rule 6(6) filing are separate duties.
5. Must the Board approve annexures before audit submission?
Rule 6(3B) requires the prescribed approval before signing on the Board’s behalf and submission to the auditor.
6. Does that approval establish later report consideration?
No. Preserve the separate rule 6(5) Board consideration evidence.
7. What accompanies a qualified report?
Full company information and explanation on every reservation or qualification under rule 6(6).
8. Can the company edit out the auditor’s reservation?
Do not alter the signed report; provide a clearly separate supported explanation.
9. Which notification replaced CRA-4 in 2025?
G.S.R. 361(E), dated 30 May 2025, effective 14 July 2025.
10. Where is the receipt-date field in that form?
Item 6(m) records the date the company received the copy of the cost-audit report.
11. Does the notified form ask for AGM-extension details?
Yes. Item 3 includes the extension question and related details.
12. Does applying for an AGM extension suffice?
The proviso refers to companies which have got the extension; retain the actual grant.
13. Do historical CRA-4 relaxations repeat automatically?
No. Check the period and conditions of the actual instrument relied on.
14. Does a later second auditor’s receipt reset an earlier report’s clock?
Do not assume so. Track each receipt and the applicable filing obligations.
15. Does successful XBRL validation establish faithful conversion?
No. Reconcile the converted content with the signed report and company explanations.
16. What proves the filing was completed?
The actual submitted package and acknowledgement, reconciled to the report and applicable deadline.
Official sources
ICMAI statutory rule text: rule 6, read with later amendments ICMAI current cost-records and audit resources MCA 3 December 2018 amendment notification, reproduced by CAIRR MCA G.S.R. 361(E), actual Gazette notification reproduced by CAIRR