Monthly Archives: February 2021

Payment of Tax by Fixed Sum Method under QRMP Scheme – GST


  1. W.e.f. 1st January, 2021, following two options are available to the Taxpayers who are under Quarterly Returns and Monthly Payment of Tax (QRMP) Scheme for tax payment for first 02 months of a quarter:
  1. Fixed Sum Method: Portal can generate a pre-filled challan in Form GST PMT-06 based on his past record.
    1. Self-Assessment Method: The Tax due is to be paid on actual supplies after deducting the Input Tax Credit available.
  • In fixed sum method, the 35% Challan can be generated by selecting the Reason For Challan>Monthly Payment for Quarterly Return> 35% Challan which is in turn calculated as per following situation:
  1. 35% of amount paid as tax from Electronic Cash Ledger in their preceding quarter GSTR 3B return, if it was furnished on quarterly basis; or
    1. 100% of the amount paid as tax from Electronic Cash Ledger in their GSTR-3B return for the last month of the immediately preceding quarter, if it was furnished on monthly basis.
  • It is to note that , for the months of Jan and Feb, 2021, in Q4 of 2020-21, the auto-populated challan generated under 35% Challan would contain 100% of the tax liability discharged from Electronic Cash Ledger for the month of December, 2020 (and not 35%). [Reason: Till December 2020, all taxpayers were filing GSTR-3B return on a monthly basis.]
  • From April, 2021 onwards, the pattern as suggested at Para 2 (a) and (b) would follow.
  • It is noteworthy, that the taxpayers are not required to deposit any amount for the first 02 months of a quarter, if:
  1. Balance in Electronic Cash Ledger / Electronic Credit Ledger is sufficient for tax due for the first/ second month of the quarter; or
    1. There is NIL tax liability

This whole scheme seems to be quite complicated. I did’nt understand a word of it, although it applies to me squarely. Strange it is that no matter how much the tax authorities try to simplify things, it becomes more complicated. This happens because they look at the things from their world point of view. It would be better if the planners place themselves in the seat of the assessee and look at the situation from their world view.

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monetary penalty on banks

RBI has vide their press release dated 3rd February, 2021 intimated regarding levying of penalty of Rs.55 lakhs on Seva Vikas Co-operative Bank Limited, Pune and Rs.1.00 lakh on The Kalpvruksha Co-operative Bank Limited, Tumkur, Karnataka.

Levy on Seva bank due to non-compliance with certain directions issued by RBI contained in the “Master Circular – Management of Advances -UCBs” and “Master Circular – Income Recognition, Asset Classification, Provisioning and Other Related Matters – UCBs.” The penalty has been imposed for not ensuring end use of funds lent (ii) non-adherence to IRAC norms and (iii) restructuring of loan accounts with retrospective effect on grounds not valid, revealed during a scrutiny of the bank conducted by RBI during 2019.

Levy on Kalpvruksha bank due to non-compliance with certain directions issued by RBI contained in the “Master Circular on Board of Directors-UCBs”. The penalty has been imposed for non-compliance by the bank with the directions prohibiting grant of loans and advances to directors, or their relatives and the firms/concerns/companies in which they are interested, as revealed during the statutory inspection of the bank with reference to its financial position as on March 31, 2019.

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de-criminalisation in LLPs

With the object of unleashing the entrepreneurial spirits of our youth and to remove the fear of criminal prosecutions for non- substantive minor and procedural omissions and commissions in the normal course of their business transactions, the Government of India in the Ministry of Corporate Affairs (MCA) decided to initiate the process of decriminalization of compoundable offences under the limited liability partnership (LLP) Act, 2008, for greater ease of doing business for law abiding LLPs.

The Government treats Honest and Ethical Corporate entrepreneurs as wealth creators and nation builders. The objective of the De-criminalization exercise is to remove criminality of offences from business laws where no malafide intentions are involved. In furtherance of the said objective, an exercise was undertaken to identify those provisions of the Limited Liability Partnership Act, violations of which do not result in injury to public interest but are presently criminal in nature with fine as well as punishment after conviction being provided for in the Act.

Principles adopted for Decriminalization of Compoundable Offences:

  1. Principle 1Offences that relate to minor/ less serious compliance issues, involving predominantly objective determinations, are proposed to be shifted to the In-house Adjudication Mechanism (IAM) framework instead of being treated as criminal offences.
  1. Principle 2: Offences that are more appropriate to be dealt with under other laws, are proposed to be omitted from the LLP Act, 2008.
  1. Principle 3For non-Compoundable offences that are very serious violations entailing an element of fraud, intent to deceive and caused injury to public interest or non- compliance of order of statutory authorities impinging on effective regulation, Status Quo would be maintained.

In all, twelve (12) offences are proposed to be decriminalized and one (1) provision (Section 73) entailing criminal liability is proposed to be omitted. The 12 de-criminalized offences would then get shifted to IAM thereby de-clogging the criminal courts from routine cases.

In addition to the De-criminalization of the Act the Government also proposes Introduction of certain new concepts into the Act for greater Ease of Doing Business:

  1. Small LLP: It is proposed to create a class of LLP called as “Small LLP” in line with the concept of Small Companies. Such Small LLPs would be subject to lesser compliances, lesser fee or additional fee and lesser penalties in the event of default. Thus, lower cost of compliance would incentivize unincorporated micro and small partnerships to convert into the organized structure of an LLP and derive its benefits.
  1. Non-convertible Debentures (NCDs):  It is proposed to allow LLPs to raise capital through issue of fully secured Non-Convertible Debentures (NCDs) (as an alternative to equity participation) from investors who are regulated by SEBI or RBI. This will help deepen the Debt Market and enhance the capitalization of LLPs.

Reduction of Additional Fee: It is also proposed to amend Section 69 of the Act with a view to reduce the additional fee of Rs. 100 per day which is presently applicable for the delayed filing of forms, documents. A reduced additional fee is expected to incentivize smooth filing of records and returns of LLPs and consequently result in an updated registry for proper regulation and policy making.

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OPC company relaxations

MCA has vide their circular dated 1st February, 2021 given some relaxations with respect of One Person Companies (OPCs) in India. These are as follows:

  1. OPC can be incorporated by a natural person who is an Indian citizen and resident in India or otherwise. Which means even non resident Indians can incorporate an OPC.
  2. The term “resident in India” means any person who has stayed in India for 182 days or more is replaced with 120 days or more. But frankly this explanation of the term resident in India should have been knocked off once the government has decided to allow resident or non resident Indians to incorporate OPC. Poor drafting.
  3. Hitherto, OPCs cannot voluntarily convert itself into other forms of company i.e. normal private limited unless 2 years has passed since its incorporation or before this period of two years, it has crossed either of the two thresholds i.e. paid up share capital of Rs.50 lakhs and average annual turnover of Rs.2 crores. Now this has been knocked off, which means that OPC can convert itself voluntarily into a normal private company at any time without considering the time factor (2 years from incorporation) or the threshold factor as above.
  4. Hitherto, OPCs was required to mandatorily convert itself into a private limited company/ public limited company only if it exceeded certain thresholds such as paid up share capital of Rs.50 lakhs and turnover of Rs. crores. Now all that mandatory clause has been knocked off. So OPCs can voluntarily convert itself whenever it wants. Which means that OPCs can exist with whatever share capital or turnover it may have. The procedures have also been simplified. Form INC-6 is required to be filed with few documents required.
  5. Similarly, hitherto private company could be converted into an OPC only if its paid up share capital was less than Rs.50 lakhs and average annual turnover is less than Rs.2 crores during the relevant period. Now these limits have been removed which means that private companies can be converted into OPCs at any level.
  6. In some places, it is “or” and some places it is “and” – which suggests poor drafting;
  7. Ease of doing business for OPCs. But OPCs did not enjoy the recent CFSS scheme, which was extended to other corporates.

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insolvency process of personal guarantor

IBBI has issued a circular dated 2nd February, 2021 wherein they have made an online process for submitting application for initiation of insolvency resolution process of a personal guarantor to a corporate debtor. This application is filed under section 94(1) or 95(1) of the Insolvency and Bankruptcy Code 2016.

On making an application online, the applicant shall get an acknowledgement.

This is one more step of making all applications online by the government.

The application can be made online at this site i.e.

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auto population of e-invoice details

update from GST portal

Auto-population of e-invoice details into GSTR-1


  1. Certain notified taxpayers have been issuing invoices after obtaining Invoice Reference Number (IRN) from Invoice Registration Portal (IRP) (commonly referred as ‘e-invoices’). Details from the reported e-invoices are being auto-populated in respective tables of GSTR-1. Update on the same was last published on last published on 11/1/2021.
  2. In the above update, it was informed that while pulling the e-invoice data into GST System, details of some invoices were not getting populated into GSTR-1. Troubleshooting has been done and efforts to correct this inadvertent gap are still on. Complete data pull is likely to take some more time.

    Hence, taxpayers are hereby advised not to wait for the complete auto-population, and instead proceed with preparation and filing of GSTR-1 (by the due date), based on actual data as per their records.

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risk based internal audit

An independent and effective internal audit function in a financial entity provides vital assurance to the Board and its senior management regarding the quality and effectiveness of the entity’s internal control, risk management and governance framework. The essential requirements for a robust internal audit function include, inter alia, sufficient authority, proper stature, independence, adequate resources and professional competence.

2. The range and commonality of risks faced by Supervised Entities (SEs) would warrant effective and harmonized systems and processes for the internal audit function across the SEs based on certain common guiding principles.

3. The introduction of Risk-Based Internal Audit (RBIA) system was mandated for all Scheduled Commercial Banks (except Regional Rural Banks) vide our circular DBS.CO.PP.BC.10/11.01.005/2002-03 dated December 27, 2002, which was further supplemented vide circular DoS.CO.PPG./SEC.04/11.01.005/2020-21 dated January 07, 2021. It has now been decided to mandate RBIA framework for the following Non-Banking Financial Companies (NBFCs) and Primary (Urban) Co-operative Banks (UCBs):

  1. All deposit taking NBFCs, irrespective of their size;
  2. All Non-deposit taking NBFCs (including Core Investment Companies) with asset size of ₹5,000 crore and above; and
  3. All UCBs having asset size of ₹500 crore and above1.

4. The Supervised Entities as indicated in Para 3 above shall implement the RBIA framework by March 31, 2022 in accordance with the Guidelines on Risk-Based Internal Audit provided in the enclosed Annex. The Guidelines are intended to enhance the efficacy of internal audit systems and processes followed by the NBFCs and UCBs.

5. Further, in order to ensure smooth transition from the existing system of internal audit to RBIA, the concerned NBFCs and UCBs may constitute a committee of senior executives with the responsibility of formulating a suitable action plan. The committee may address transitional and change management issues and should report progress periodically to the Board and senior management.

6. This circular should be placed before the Board in its next meeting. The implementation of these guidelines as per timeline specified should be done under the oversight of the Board.


Ref. No.DoS.CO.PPG./SEC.05 /11.01.005/2020-21 dated February 03, 2021

Guidelines on Risk-Based Internal Audit (RBIA) System for Select NBFCs and UCBs

RBI vide circular DBS.CO.PP.BC.10/11.01.005/2002-03 dated December 27, 2002, had introduced Risk-Based Internal Audit (RBIA) system in Scheduled Commercial Banks (SCBs) as part of their internal control framework, which was further supplemented vide circular DoS.CO.PPG./SEC.04/11.01.005/2020-21 dated January 07, 2021. This framework relies broadly on a well-defined policy for internal audit, functional independence with sufficient standing, effective channels of communication and adequate audit resources with sufficient professional competence.

While NBFCs (Non-Banking Financial Companies) and Primary (Urban) Cooperative Banks (UCBs) have grown in size and become systemically important, prevalence of different audit system/approaches in such entities has created certain inconsistencies, risks and gaps. As SCBs, NBFCs and UCBs face similar risks by virtue of being engaged in similar financial intermediation activities, their internal audit systems also need to broadly align while keeping in mind the principle of proportionality. Considering these aspects, the Guidelines herein prescribe the broad principles that should be followed by NBFCs and UCBs to enable them to gradually move towards an RBIA system.

A. Objectives and Scope

1. An effective Risk-Based Internal Audit (RBIA) is an audit methodology that links an organisation’s overall risk management framework and provides an assurance to the Board of Directors and the Senior Management on the quality and effectiveness of the organisation’s internal controls, risk management and governance related systems and processes.

2. The internal audit function should broadly assess and contribute to the overall improvement of the organization’s governance, risk management, and control processes using a systematic and disciplined approach. The function is an integral part of sound corporate governance and is considered as the third line of defence.

3. Historically, the internal audit system in NBFCs/UCBs has generally been concentrating on transaction testing, testing of accuracy and reliability of accounting records and financial reports, adherence to legal and regulatory requirements, etc. However, in the changing scenario, such testing by itself might not be sufficient. Therefore, SEs will have to move towards a framework which will include, in addition to selective transaction testing, an evaluation of the risk management systems and control procedures in various areas of operations. This will also help in anticipating areas of potential risks and mitigating such risks.

4. While the Risk Management Function should focus on identification, measurement, monitoring, and management of risks, development of risk policies and procedures, use of risk management models, etc., RBIA should undertake an independent risk assessment for the purpose of formulating a risk-based audit plan which considers the inherent business risks emanating from an activity / location and the effectiveness of the control systems for monitoring such inherent risks.

Expectations on the roles and responsibilities of different functionaries for this internal audit framework are provided in the following paragraphs.

B. Board of Directors / Audit Committee of Board

1. The Board of Directors (the Board) / Audit Committee of Board (ACB) of NBFCs and the Board of UCBs are primarily responsible for overseeing the internal audit function in the organization. The RBIA policy shall be formulated with the approval of the Board and disseminated widely within the organization. The policy shall clearly document the purpose, authority, and responsibility of the internal audit activity, with a clear demarcation of the role and expectations from Risk Management Function and Risk Based Internal Audit Function. The policy should be consistent with the size and nature of the business undertaken, the complexity of operations and should factor in the key attributes of internal audit function relating to independence, objectivity, professional ethics, accountability, etc. The RBIA policy must be reviewed periodically.

2. The internal audit function shall be carried out effectively so as to ensure that it adds value to the organization. For the purpose, the ACB/Board shall approve a RBIA plan to determine the priorities of the internal audit function based on the level and direction of risk, as consistent with the entity’s goals. The risk assessment of business and other functions of the organization shall at the minimum be conducted on an annual basis. Every activity / location, including the risk management and compliance functions, shall be subjected to risk assessment by the RBIA. The policy should also lay down the maximum time period beyond which even the low risk business activities / locations would not remain excluded for audit.

3. The ACB/Board is expected to review the performance of RBIA. The ACB/Board should formulate and maintain a quality assurance and improvement program that covers all aspects of the internal audit function. The quality assurance program may include assessment of the internal audit function at least once in a year for adherence to the internal audit policy, objectives and expected outcomes. Further, ACB/Board shall promote the use of new audit tools/ new technologies for reducing the extent of manual monitoring / transaction testing / compliance monitoring, etc.

C. Senior Management

1. The senior management is responsible for ensuring adherence to the internal audit policy guidelines as approved by the Board and development of an effective internal control function that identifies, measures, monitors and reports all risks faced. It shall ensure that appropriate action is taken on the internal audit findings within given timelines and status on closure of audit reports is placed before the ACB/Board.

2. The senior management is responsible for establishing a comprehensive and independent internal audit function which should promote accountability and transparency. It shall ensure that the RBIA Function is adequately staffed with skilled personnel of right aptitude and attitude who are periodically trained to update their knowledge, skill and competencies.

3. A consolidated position of major risks faced by the organization shall be presented at least annually to the ACB/Board, based on inputs from all forms of audit.

D. Internal Audit Function

The internal audit function should assess and make appropriate recommendations to improve the governance processes on business decision making, risk management and control; promote appropriate ethics and values within the organization; and ensure effective performance management and staff accountability, etc.

The following key-attributes need to be observed:

I. Authority, Stature, Independence and Resources

The internal audit function must have sufficient authority, stature, independence and resources thereby enabling internal auditors to carry out their assignments properly. The Head of Internal Audit (HIA) shall be a senior executive with the ability to exercise independent judgement. The HIA and the internal audit functionaries shall have the authority to communicate with any staff member and get access to all records that are necessary to carry out the entrusted responsibilities.

II. Competence

Requisite professional competence, knowledge and experience of each internal auditor is essential for the effectiveness of internal audit function. The areas of knowledge and experience may include banking/financial entity’s operations, accounting, information technology, data analytics, forensic investigation, among others. The collective skill levels should be adequate to audit all areas of the SE.

III. Rotation of Staff

Except for the entities where the internal audit function is a specialised function and managed by career internal auditors, the Board should prescribe a minimum period of service for staff in the internal audit function. The Board may also examine the feasibility of prescribing at least one stint of service in the internal audit function for those staff possessing specialized knowledge useful for the audit function, but who are posted in other areas, so as to have adequate skills for the staff in the internal audit function.

IV. Tenor for appointment of Head of Internal Audit

Except for the entities where the internal audit function is a specialised function and managed by career internal auditors, the HIA shall be appointed for a reasonably long period, preferably for a minimum of three years.

V. Reporting Line

The HIA shall directly report to either the ACB/Board/ MD & CEO or to the Whole Time Director (WTD). Should the Board of Directors decide to allow the MD & CEO or a WTD to be the ‘Reporting authority’, then the ‘Reviewing authority’ shall be the ACB/Board and the ‘Accepting authority’ shall be the Board in matters of performance appraisal of the HIA. Further, in such cases, the ACB/Board shall meet the HIA at least once in a quarter, without the presence of the senior management (including the MD & CEO/WTD). The HIA shall not have any reporting relationship with the business verticals of these SEs and shall not be given any business targets.

VI. Remuneration

The independence and objectivity of the internal audit function could be undermined if the remuneration of internal audit staff is linked to the financial performance of the business lines for which they exercise audit responsibilities. Thus, the remuneration policies should be structured in a way to avoid creating conflict of interest and compromising audit’s independence and objectivity.

VII. Responsibilities and Other General Expectations

1. The internal audit function should work on the basis of established policies and procedures as approved by the ACB/Board.

2. The internal audit shall undertake an independent risk assessment for the purpose of formulating a risk-based audit plan. This risk assessment would cover risks at various levels/areas (corporate and branch, the portfolio and individual transactions, etc.) as also the associated processes.

3. The risk assessment in the internal audit department should be used for focusing on the material risk areas and prioritizing the audit work.

4. The risk assessment process should, inter alia, include identification of inherent business risks in various activities undertaken, evaluation of the effectiveness of the control systems for monitoring the inherent risks of the business activities (‘Control risk’) and drawing-up a risk-matrix for both the factors viz., inherent business risks and control risks.

5. The basis for determination of the level (high, medium, low) and trend (increasing, stable, decreasing) of inherent business risks and control risks should be clearly spelt out.

6. The risk assessment may make use of both quantitative and qualitative approaches. While the quantum of credit, market, and operational risks could largely be determined by quantitative assessment, the qualitative approach may be adopted for assessing the quality of overall governance and controls in various business activities.

7. The risk assessment methodology should include, inter alia, parameters such as (a) Previous internal audit reports and compliance; (b) Proposed changes in business lines or change in focus; (c) Significant change in management / key personnel; (d) Results of regulatory examination report; (e) Reports of external auditors; (f) Industry trends and other environmental factors; (g) Time elapsed since last audit; (h) Volume of business and complexity of activities; (i) Substantial performance variations from the budget; and (j) Business strategy of the entity vis-à-vis the risk appetite and adequacy of control.

8. For the risk assessment to be accurate, it will be necessary to have proper MIS and data integrity arrangements. The internal audit function should be kept informed of all developments such as introduction of new products, changes in reporting lines, changes in accounting practices / policies, etc. The risk assessment should invariably be undertaken on a yearly basis. The assessment should also be periodically updated to take into account changes in business environment, activities and work processes, etc.

9. Before taking up specific internal audit assignment, the plan, scope, objectives, timelines and resource allocations of the assignment should be clearly established. The scope and objectives of the assignment should be based on a preliminary assessment of the risks relevant to the business activity under review.

10. The SEs may prepare a Risk Audit Matrix based on the magnitude and frequency of risk. The Audit Plan should prioritize audit work to give greater attention to the areas of:

  1. High magnitude and high frequency
  2. High magnitude and medium frequency
  3. High magnitude and low frequency
  4. Medium magnitude and high frequency
  5. Medium magnitude and medium frequency
  6. Low magnitude and high frequency.

11. The scope of the audit and resource allocation should be sufficient to achieve the objectives of the audit assignment. The precise scope of RBIA must be determined by each SE for low, medium, high, very high and extremely high risk areas. The scope of internal audit should also include system and process audits in respect of all critical processes. The findings of such audits should also be placed before the IT Committee of the Board.

12. The internal audit report should be based on appropriate analysis and evaluation. It should bring out adequate, reliable, relevant and useful information to support the observations and conclusions. It should cover the objectives, scope, and results of the audit assignment and make appropriate recommendations and / or action plans.

13. All the pending high and medium risk paras and persisting irregularities should be reported to the ACB/Board in order to highlight key areas in which risk mitigation has not been undertaken despite risk identification.

14. The internal audit function should have a system to monitor compliance to the observations made by internal audit. Status of compliance should be an integral part of reporting to the ACB/Board.

15. The internal audit function shall not be outsourced. However, where required, experts including former employees can be hired on a contractual basis subject to the ACB/Board being assured that such expertise does not exist within the audit function of the SE. Any conflict of interest in such matters shall be recognised and effectively addressed. Ownership of audit reports in all cases shall rest with regular functionaries of the internal audit function.

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Who’s Afraid of Virginia Woolf

“Who’s Afraid of Virginia Woolf” (1966) a disturbing black comedy based on Edward Albee’s play of the same name, directed by Mike Nichols and starring Elizabeth Taylor, Richard Burton, George Segal and Sandy Dennis.

The movie is breathtakingly intense and at the same time there is an underlying sadness to it, when you understand the context. George (Richard Burton) is a history professor and Martha (Elizabeth Taylor) his wife. George teaches at the university at Martha’s father is the Dean. They are fiftyish and furiously quibbling with each other.

Martha has invited another young couple Nick (George Segal in a brilliant role) and Honey (Sandy Dennis in an award winning performance) to their house for drinks. Nick is also the biology professor in the same college.

What happens in the house after the guests come in is intense word play between Martha and George which surprises the guests. Both Martha and George quarrel openly in front of the guests, making them wonder if they have done the right thing to come there.

Most of the shooting is inside their cramped house so that makes it more suffocating. Then George and Nick go outside when Honey throws up and then they go for a drive with George driving in an inebriated state. All the while George and Martha continue their bickering.

Martha talks about their son which enrages George. That is a taboo for him which makes him angry like hell. Their sado-masochism is an escape for their deep failure which they know for a fact and can’t do anything about it. Beneath their bravado lies deep insecurity and sadness and anguish.

Elizabeth has done the role of her lifetime in this movie. She is simply breathtaking especially towards the end when she realises the secret about her son is going to be revealed, she is quite magnificient. She of course won the Best Actress award at the Oscars for this picture.

Richard Burton is of course brilliant as usual with his lines and his arrogance and his wit and ruthlessness. George Segal has acted superbly i thought but Sandy Dennis won the best supporting award at the Oscars. This is one movie which got nominated in every category of that year.

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companies amendment act 2020

Few sections of the companies amendment act 2020 has been notified from 22nd January, 2021. Given below some important amendments likely to affect corporates.

Section 129A – being introduced into the companies act, 2013 to provide for financial statements on periodical basis for unlisted companies. The provision for audit or limited review of such financial statement and their filings with the ROC will be notified in the Rules. 

This pre-supposes that certain unlisted public limited companies or big private companies based upon turnover criteria would be required to submit their quarterly or half yearly accounts also. What purpose it serves to have such micro management of small companies, it is not clear.

Section 135 – Corporate Social Responsibility – some major amendments here

A proviso is added to section 135(5) that if a company spends in excess of the requirements under the Act, then such excess can be set off against future years. How many number of financial years it can be carried forward and the manner of doing so, will be notified in the Rules. 

Sec 135(7) is amended which provides that if the company is in contravention of sub-sections (5) or (6) then the company is laible to penalty of twice the amount required to be transferred by the company to a Fund specified in Schedule VII or Unspent Corporate Social Responsibility account or Rs.1 crore whichever is less. Every officer in default shall be liable to a penalty of 1/10th of the above two amounts or Rs.2 lakhs whichever is less. Section 135(5) pertains to spending of the CSR amount in a year i.e. two % of the average net profits during the immediately preceding 3 financial years. Sec 135(6) pertains to the CSR amount to be transferred to Unspent CSR a/c or to the fund specified in Schedule VI. But the changes specified in section 135(6) is not notified yet. 

Further a new sub-section (9) has been added in section 135 which specifies that where the amount of CSR to be spent does not exceed Rs.50 lakhs, then there is no need to constitute a separate CSR Committee in such case and the Board of Directors shall perform the functions of the CSR Committee. 

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