Facts of the
Case
The complainant, Ms. M. Roopa, IPS, Superintendent
of Police, Central Bureau of Investigation, Anti-Corruption Branch, Chennai,
filed a complaint against the respondent, CA Devarajan K.E., alleging serious
professional misconduct connected with bank fraud involving M/s Swastik
Enterprises. The allegations arose out of a CBI investigation relating to
sanction and misuse of credit facilities from Canara Bank.
It was alleged that the respondent assisted the
proprietor of M/s Swastik Enterprises in preparation of fudged financial
statements for the years ending 31.03.2008 and 31.03.2009 by inflating capital
and suppressing unsecured loans and liabilities. The respondent also prepared
Credit Monitoring Arrangement (CMA) data submitted to Canara Bank on the basis
of manipulated financials, which materially differed from balance sheets filed
with the Income Tax Department. Further allegations included collusion with bank
officials and advising the proprietor to avail foreign bills purchase limits
without actual exports, and receipt of illegal payments aggregating to
₹46,46,500 routed through cheques issued to third parties and the respondent’s
wife.
Issues
Involved
Whether the respondent Chartered Accountant was
guilty of “Other Misconduct” under Clause (2) of Part IV of the First Schedule
to the Chartered Accountants Act, 1949 for preparing and submitting manipulated
CMA data, facilitating suppression of liabilities, colluding in bank fraud, and
receiving illegal payments.
Petitioner’s
Arguments
The complainant department alleged that the
respondent knowingly prepared CMA data using falsified financial statements
signed by another Chartered Accountant, despite being aware that such figures
did not tally with audited balance sheets submitted to the Income Tax
Department. It was contended that the respondent actively assisted the
proprietor and bank officials in deceiving the bank to obtain enhanced credit
limits and received illegal gratification for the same. Statements of bank
officials, company employees and third parties, along with documentary evidence
including loan proposals, balance sheets, payment records and vehicle purchase
documents, were relied upon to establish misconduct.
Respondent’s
Arguments
The respondent contended that he had merely
prepared CMA data based on information provided and that he was not the auditor
of the financial statements. He claimed that all professional receipts were
disclosed to tax authorities and denied involvement in collusion or receipt of
illegal payments. The respondent sought adjournments on multiple occasions and
did not produce substantive evidence to rebut the documentary material relied
upon by the complainant department.
Court Order
/ Findings
The Board of Discipline examined the findings
recorded under Rule 14(9), documentary evidence, witness statements and the
respondent’s submissions. The Board observed that the CMA data prepared by the
respondent showed capital figures significantly higher than those reflected in
balance sheets filed with the Income Tax Department, achieved by clubbing
unsecured loans and advances into capital to suppress liabilities. The Board
held that the respondent, being a Chartered Accountant, was duty-bound to
verify the authenticity and genuineness of financial data used for bank
verification and could not disclaim responsibility.
The Board further relied on statements of bank
officials and third parties establishing that the respondent acted as a de
facto controller of the concern’s banking affairs, advised on misuse of foreign
bill facilities, and received payments amounting to ₹46,46,500, including
payments routed to his wife and for purchase of a vehicle. The respondent
failed to produce any credible evidence to negate these findings. The Board
concluded that the respondent deliberately assisted in financial manipulation
and bank fraud, constituting conduct unbecoming of a Chartered Accountant.
Important
Clarification
The Board clarified that preparation of CMA data
based on falsified financial statements, without due diligence and
verification, amounts to grave misconduct. A Chartered Accountant cannot escape
liability by claiming non-audit status when knowingly facilitating submission
of misleading financial information to banks or financial institutions.
Final
Outcome
The Board of Discipline, ICAI, held that CA
Devarajan K.E. was GUILTY of Other Misconduct under Clause (2) of Part IV
of the First Schedule to the Chartered Accountants Act, 1949 read with Section
22. In exercise of powers under Section 21A(3), the Board reprimanded
the respondent by order dated 12.06.2024, after reconsideration pursuant
to directions of the Hon’ble Madras High Court.
Source Link - https://mytaxexpert.co.in/uploads/1768816259_Ms.M.RoopaIPSvs.CADevarajanK.E.BoardofDisciplineICAI.pdf
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