QUESTIONS 1.     Cost Accounting Record Rules1.1.          Do you agree with the Expert Group to shift maintenance of cost records from existing rule/format-based to principle-based having universal application?1.2.          If yes, do you propose repeal of all the existing Cost Accounting Record Rules and in place, Government may prescribe maintenance of cost records based on generally accepted cost accounting principles and cost accounting standards?1.3.          Do you agree that under the principle-based accounting system, all companies should maintain cost records as an integral part of books of accounts, but to be left free to follow relevant method of cost management?1.4.          Maintenance of cost data/records, as an integral part of the books of accounts, does not normally entail any additional cost to the companies. However, do you agree that the above mechanism of moving away from rule/format based to principle based maintenance of cost data/records will provide due flexibility to the companies and reduce compliance cost, if any, further? 2.     Cost Audit Report Rules2.1.          Do you agree with the revised structure of cost audit broadly proposed by the Expert Group?2.2.          Do you agree that there should be a threshold limit for exemption from cost audit? If yes, what threshold limit would you like to suggest? Should the exemption limit be equal to:2.2.1.         Annual turnover of Rs.10/20/25/50 crores; or2.2.2.         Paid-up capital or Net Worth or Investment in Fixed Assets of Rs.5/10 crores; or2.2.3.         10%/20%/50% level of public participation (including through Banks/FIs /MFs) in share capital as well as loans; or2.2.4.         A combination of above?2.3.    Would you recommend e-filing a combined cost audit report with the Government (i.e. MCA) containing only a simple abridged cost statement?2.4.    Do you agree that any Government organisation or the Regulators may be left free to directly seek copy of the detailed cost audit report and such additional cost details from the relevant companies as may be prescribed by them?2.5.          Internationally accepted basic dictum of any audit is, it should be “independent”. In view of this, how would you suggest the mechanism to appoint the cost auditors?2.5.1.        Should the existing mechanism of appointment of cost auditor be continued i.e. the Board of Directors (BOD) will appoint with the prior approval of the Central Government; or2.5.2.        The Board of Director may appoint without any approval of the Central Government; or2.5.3.        The shareholders in AGM should appoint the cost auditors?2.6.          Further, do you suggest that in case of exempted companies, the power to get the cost records audited be vested with the 10% shareholders by making a request to the Government? 2.7.          Similarly, would you also suggest that in such companies, a right be vested in secured creditors with stakes more than 50% of net worth to seek a special audit of the cost records of the company?2.8.          As proposed by CII, would you suggest circulation of any part of cost management trends to the shareholders?2.9.          What should be the periodicity of cost audit? Should it be annual or half-yearly or quarterly linked with the corporate governance and segmental reporting (atleast in case of listed companies)?2.10.      Do you agree that the above mechanism would provide complete confidentiality and fuller utility of sensitive cost data? 3.     Cost Accounting Standards3.1.          Do you agree that for ensuring a complete shift from the existing rule-based to principle-based cost accounting & audit mechanism and also for the sake of uniformity in preparing accepted cost statements under WTO and other Statutes, there is an urgent need for the country to have Cost Accounting Standards based on generally accepted cost accounting principles?3.2.          If yes, would you agree that all companies should be asked to comply with such cost accounting standards?3.3.          If yes, do you also agree that ICWAI should assign topmost priority for issue of cost accounting standards in consultation with all stakeholders?3.4.          Would you suggest that all cost accounting standards should be aligned with the cost accounting standards issued by other developed countries, international best practices, IFRS, and other IFAC guidelines? 4.     Other Related Sectors4.1.          Do you agree with the Expert Group views that there is need to extend the existing principles & practices of cost accounting and cost audit to the services and other social sectors such as healthcare, education, banking, insurance, financial services, public utilities such as municipalities, electricity, water supply, city transportation, etc?4.2.          Similarly, do you also agree extending this framework to various Government projects/schemes, departmental undertakings, such as ordnance factories, railway locomotive/coaches manufacturing units, etc? 4.3.          Presently, fees charged by various public service organisations do not show any correlation with the costs. In light of this, do you agree that all Government agencies should determine user charges based on most efficient costs?