CS Anupam Gupta worked as Chief Compliance Officer (CCO) with PQR Limited till 31/08/2024. Since he got lucrative offer from XYZ Limited, he could not resist and joined on 1/09/2024 as CCO there. Because of differences o

CS Professional · Compliance Management, Audit and Due Diligence · PYQS · June 2026
CS Anupam Gupta worked as Chief Compliance Officer (CCO) with PQR Limited till 31/08/2024. Since he got lucrative offer from XYZ Limited, he could not resist and joined on 1/09/2024 as CCO there. Because of differences of opinion with management, he had to leave that organisation on 31/10/2025. Post this incidence, he was in dilemma and searching for a suitable opportunity. In the meantime, his friend informed him about an opening with ABC & Company, (Company Secretarial Firm) where he applied and joined with effect from 01/02/2026. Because of his contacts, he was able to secure a secretarial audit assignment for the firm for FY 2026-27 of MNC limited which is the subsidiary of PQR Limited where he already worked as CCO. Analyse and decide whether ABC & Company should take up the Secretarial Audit Assignment for the FY 2026-27?

Answer & Explanation:

CSAS-1 Auditing Standard on Audit Engagement issued by the ICSI provides that the Auditor shall not have any substantial conflict of interest with the Auditee. Where an Auditor was in employment of the Auditee, its holding or subsidiary company and 2 (two) years have not lapsed from the date of cessation of employment, the same shall be considered as substantial conflict of interest. A PCS or member/partner of a PCS firm cannot undertake the audit of that undertaking where the member was in employment prior to holding the Certificate of Practice, unless two years have lapsed from the date of cessation of employment. Conclusion: In the given case, substantial conflict of interest with PQR Ltd. and its subsidiary MNC Ltd., will be applicable only if CS Anupam Gupta has joined as Partner of the ABC & Company. If CS Anupam Gupta has joined the ABC & Company as an employee, then the firm ABC & Company can take the secretarial audit of MNC Limited for the Financial Year 2026-27.

Topics: Secretarial Audit

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