Ind As Implementation Guide
Ind As Implementation Guide
Ind As Implementation Guide
Implementation
Guide
February 2020
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Foreword
About Indian Accounting Standards (Ind AS)
implementation in India
Ind AS involve application of several new and
complex concepts, which require a significant level of
judgement and estimation, accompanied by detailed
qualitative and quantitative disclosures. As Indian
entities gain experience of implementing Ind AS, they
should also support consistent application of the
standards.
The Ind AS Technical Facilitation Group (ITFG)
The Accounting Standards Board (ASB) of the
Institute of Chartered Accountants of India (ICAI)
constituted the ITFG to provide clarifications on
various issues related to the applicability of Ind AS
and its implementation. The preparers, users and
other stakeholders have raised a number of issues to
ITFG. Till date, ITFG has issued 23 bulletins covering
complex implementation issues on various Ind AS
such as, revenue from contracts with customers,
leases, consolidation, financial instruments, business
combinations, income taxes, etc.
Educational Materials (EMs) on Ind AS
The ICAI through its Ind AS implementation group has
brought out 14 EMs till date on various Ind AS such as
revenue from contracts with customers, presentation
of financial statements, consolidation, business
combinations, leases, etc. The EMs are in the form
of Frequently Asked Questions (FAQs) which cover
Ind AS implementation issues which are expected
to be encountered frequently while implementing a
standard.
Expert Advisory Opinions (EACs) on Ind AS
The Expert Advisory Committee (the committee) of
the ICAI has till date issued 21 EACs on some key
implementation issues under various Ind AS. These
EACs are based on the facts and circumstances
of each case as presented to the committee, the
accounting/auditing principles and practices and the
relevant laws applicable on the dates the committee
finalised the respective EAC opinions.
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About the publication the ITFG clarifications. These are expected to assist
Our publication ‘Ind AS Implementation Guide’ is companies in effective implementation of Ind AS and
designed to assist companies in understanding guidance provide a context for users of financial statements
and key principles on Ind AS issued in the various ITFG to better understand the information reported by
Bulletins, EMs and Ind AS EAC opinions when preparing companies under Ind AS.
financial statements in accordance with Ind AS. The EAC opinions
publication is designed to provide a brief overview of For ease of understanding and use, we have included in
the Ind AS and highlights the key differences from the every chapter a summary of key takeaways from the Ind
respective International Financial Reporting Standards AS EAC opinions issued by ICAI.
(IFRS). It contains 10 chapters, which provide an
essence of the principles within Ind AS pertaining to References to EMs
each topic. Some chapters may contain multiple topics/ This section contains a reference of the issues
Ind AS application issues. discussed in the EM pertaining to a standard in the form
The publication is based on the Ind AS notified by the of a table.
Ministry of Corporate Affairs (MCA), including Ind AS Need for judgement
115 and Ind AS 116. It also includes all the issues of the This publication intends to highlight some of the
23 clarifications’ bulletins that have been issued by practical application issues with the help of certain facts
ITFG till 10 February 2020, reference to 14 EMs and key and circumstances detailed in the examples used. In
principles highlighted in the 21 EAC opinions on Ind AS practice, transactions or arrangements involving Ind
issued by the ICAI. AS may be complex. Therefore, further interpretation
Each chapter includes the sections below: and significant use of judgement may be required for
an entity to apply Ind AS to its facts, circumstances
Key principles
and individual transactions. Further, some information
This section provides a brief overview of the significant contained in this publication may change as practice and
principles prescribed within Ind AS covered by the implementation guidance continue to develop. Users
chapter. It highlights key principles articulated in the are advised to read this publication in conjunction with
specific Ind AS to assist preparers and other users of the actual text of the standards and implementation
financial statements in understanding the significant guidance issued, and to consult their professional
requirements related to the topics covered in each advisors before concluding on accounting treatments for
chapter. their transactions.
Significant differences from IFRS References
While Ind AS is largely converged with the IFRS issued References to relevant guidance and abbreviations,
by the International Accounting Standards Board when used, are defined within the text of this
(IASB), there are certain additional requirements/ publication.
exemptions provided in Ind AS, or certain requirements/
exemptions provided in IFRS that have been excluded
from Ind AS, known as ‘carve-outs’ from IFRS. These
divergences from IFRS are intended to smoothen the
implementation and applicability of the standards from
an Indian context.
Post implementation of Ind AS, many corporates
may continue to report under the IFRS framework.
This publication therefore highlights the significant
differences from IFRS in each chapter.
Practical implications arising out of ITFG clarifications
This section summarises the various Ind AS clarifications
issued by the ITFG in simple and easy to understand
Sai Venkateshwaran Ruchi Rastogi
Partner and Head Partner
language. Our publication captures their essence CFO Advisory Assurance
by highlighting the key principles that emerge from KPMG in India KPMG in India
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Table of
contents
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Sr. No. Topic Page No.
1. Consolidation 1
2. Business combinations 15
3. Financial instruments 25
4. Tangibles and Intangibles Assets 47
5. Income taxes 57
6. Revenue 67
7. Leases 75
8. Effects of changes in foreign exchange rates 87
9. First-time adoption of Ind AS 91
10. Other topics 109
Presentation of Financial Statements
Statement of Cash Flows
Accounting Policies, Changes in Accounting Estimates and Errors
Accounting for Government Grants and Disclosure of Government Assistance
Borrowing Cost
Related Party Disclosures
Separate Financial Statements
Earnings per Share
Provisions, Contingent Liabilities and Contingent Assets
Operating Segments
Applicability of Ind AS
Other opinions by EAC
Other EMs
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1
1. Consolidation
Summary
This chapter covers:
• Ind AS 110, Consolidated Financial Statements
• Ind AS 111, Joint Arrangements
• Ind AS 28, Investments in Associates and Joint Ventures
In India, the Companies Act, 2013 (2013 Act), mandates preparation of Consolidated Financial
Statements (CFS) in addition to the requirement of preparing Separate Financial Statements (SFS),
if a company has one or more subsidiaries, associates or joint ventures. Ind AS 110 establishes
principles for the presentation and preparation of CFS when an entity controls one or more other
entities.
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Ind AS Implementation Guide I 2
Key principles
• An investor controls an investee when the former • Losses relating to subsidiaries have to be attributed
is exposed to, or has rights, to variable returns from to NCI, even if it results in a negative balance.
its involvement with the investee and has the ability
• A limited exemption from consolidation is available
to affect those returns through its power over the
to an investment entity, which is not required to
investee.
consolidate its subsidiaries if it measures all of
• Only substantive rights are considered while its subsidiaries at fair value through profit or loss in
assessing whether an investor controls the relevant accordance with Ind AS 109, Financial Instruments.
activities.
• An associate is an entity over which the investor
Significant differences from IFRS1
has significant influence which is the power to
participate in the financial and operating policy • IAS 28, Investment in Associates and Joint
decisions of the investee but is neither control nor Ventures, requires that for the purpose of
joint control of those policies. applying equity method of accounting in
• If an entity holds, directly or indirectly (e.g. through the preparation of an investor’s financial
subsidiaries), 20 per cent or more of the voting statements, uniform accounting policies should
power of the investee, it is presumed that the entity be used. In other words, if the associate’s
has significant influence, unless it can be clearly accounting policies are different from those of
demonstrated that this is not the case. Conversely, the investor, the investor should change the
if the entity holds, directly or indirectly (e.g. through financial statements of the associate by using
subsidiaries), less than 20 per cent of the voting the same accounting policies.
power of the investee, it is presumed that the entity • In Ind AS 28, the phrase, ‘unless impracticable
does not have significant influence, unless such to do so’ has been added in the requirement
influence can be clearly demonstrated. A substantial for uniform accounting policies. This has been
or majority ownership by another investor does done, since certain associates, for example,
not necessarily preclude an entity from having Regional Rural Banks (RRBs), being associates
significant influence. of nationalised banks, are not in a position to
• A joint arrangement is an arrangement over which use the Ind AS as these may be too advanced
two or more parties have joint control. There are two for RRBs.
types of joint arrangements - a joint operation and • IAS 28 requires any excess of the investor’s
joint venture. share of net assets in an associate over the
• Non-Controlling Interests (NCI) in subsidiaries acquisition cost to be recognised as a gain in
is required to be presented in the consolidated the profit and loss account. Ind AS 28 requires
balance sheet within equity, separately from the such a gain to be recognised as a capital
equity of the owners of the parent. reserve in the balance sheet.
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3
A Ltd. C Ltd.
Warrants
26% B Ltd.
In a certain situation, an entity (A Ltd.), invested 26 B Ltd. is an associate company of C Ltd. since C Ltd.
per cent in another entity B Ltd. and accounted it as an has potential voting rights over B Ltd.
associate for statutory reporting requirements under
In the given scenario, in accordance with Ind AS, B
previous GAAP. Another entity C Ltd. owned share
Ltd. also ceases to be an associate of A Ltd. Therefore,
warrants that were convertible into equity shares of B
B Ltd. need not to comply with Ind AS from the
Ltd. and had potential voting rights, which if exercised
financial year 2016-17 though the company was an
would give additional voting power to C Ltd. over the
associate company of A Ltd. under previous reporting
financial and operating policies of B Ltd.
framework.
The definitions given in Ind AS would be applied both
If C Ltd. voluntarily complies with Ind AS or meets
for the purpose of preparing financial statements and
any specified criteria on standalone basis, then B Ltd.
determining the relationship with another entity (i.e.
being its associate company as per Ind AS 28 should
subsidiary, associate, joint venture, etc.)
comply Ind AS from the same financial year from
In the present case, by applying the relevant which C Ltd. starts preparing financial statements as
requirements of Ind AS 28, it has been concluded that per Ind AS. (ITFG3, Issue 5)
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Ind AS Implementation Guide I 4
In the Year 1
Funds from several overseas investors
A Ltd.
(investment
entity)
I. II. III.
(Start-up ) (Start-up ) (Start-up )
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5
incorporates
A Ltd. (investment entity) S Ltd.
Funds from several (wholly owned
overseas investors subsidiary)
A Ltd. does not have any exit strategy in place for its In the Year 2
investments in S Ltd. In its CFS, A Ltd. values the The above position continues in Year 2.
investments in start-up subsidiaries at Fair Value
Through Profit and Loss (FVTPL) and consolidate In the Year 3 (i.e. the year of re-structuring)
S Ltd. as per Ind AS 110. A Ltd. transfers investments (in start-ups and S Ltd.)
to a newly formed wholly- owned subsidiary, B Ltd.
against shares in B Ltd.
A Ltd. S Ltd.
B Ltd.
A Ltd. does not have any exit strategy in place for its
investment in B Ltd., but the exit strategies for each of Ind AS 110 provides that an investment entity is
the investments in start-up companies continue to be not required to have a potential exit strategy for
in place. its investment in another investment entity that
was formed in connection with the entity for legal,
ITFG clarified on the following accounting issues:
regulatory, tax or similar reasons, provided that
In the post-restructuring scenario, whether A Ltd. the investment entity investee has a potential exit
is still an investment entity? strategy for all of its investments that could be
In the post-restructuring scenario, A Ltd. holds the held indefinitely.
investments in subsidiaries indirectly through B Ltd.
Further, B Ltd. satisfies all the three conditions of It was concluded in this case that even though A
definition of the investment entity as given in Ind AS Ltd. does not have an exit strategy in respect of B
110 for classification as an investment entity. Ltd., it still qualifies as an investment entity since B
While A Ltd. has no exit strategy in place for its Ltd. has exit strategies in place in respect of start-
investment in B Ltd., exit strategies for each of the up companies and satisfies the other conditions for
investments in start-up companies are still in place. classification as an investment entity.
Hence, in the given case A Ltd. is an investment entity
in the post-restructuring scenario also.
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Ind AS Implementation Guide I 6
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7
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Ind AS Implementation Guide I 8
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9
Loss of control
Equity accounting in the CFS of investor in case of
loss of control
In a scenario, an entity B Ltd., a subsidiary of another
entity A Ltd. (parent), owned an investment property
that was measured at cost in accordance with Ind AS
40, Investment Property, A Ltd. sold a portion of its
equity shareholding in B Ltd., and consequently B Ltd.
became a joint venture between A Ltd. and another
entity Z Ltd.
In accordance with the requirements of Ind AS 28
equity method is required to be applied in the CFS of
A Ltd. to account for its investment in the joint venture
(i.e. B Ltd.). Thus, in CFS of A Ltd., equity method
requires the identifiable assets and liabilities of the
investee (i.e. B Ltd.) be fair valued and appropriate
adjustments be made to an entity’s (i.e. A Ltd.’s) share
of investee’s profit or loss.
Ind AS 40, however, does not allow an investment
property to be measured at fair value.
The ITFG considered two accounting issues as
following:
• Whether any contradiction exists between Ind
AS 40 and Ind AS 28
From the perspective of an investor who acquires, a
controlling interest in an entity (or an interest giving
the investor joint control or significant influence over
the investee), Ind AS require the investor to identify
whether it has made a bargain purchase gain or
whether the consideration includes an element of
payment for goodwill. The amount of any bargain
purchase gain or of any payment for goodwill would
be determined with reference to the fair values of the
identifiable assets and liabilities of the investee as at
the acquisition date and not with reference to their
book values as at that date.
Accordingly, the relevant standard (e.g. Ind AS 28 in
the case of a joint venture or an associate) requires
determination of fair values of identifiable assets and
liabilities of the investee for this purpose. This fair
value requirement does not indicate a contradiction
between Ind AS 28 (or Ind AS 110 in case of acquisition
of a controlling interest) on one hand and the standards
that require a cost based measurement in the balance
sheet of the investee on the other.
Therefore, ITFG clarified that there does not seem any
contradiction between Ind AS 40 and Ind AS 28.
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Ind AS Implementation Guide I 10
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Ind AS Implementation Guide I 12
Assessment of control1 when investments in shares are managed by a fund manager (agent vs.
21
principal evaluation)
22 Accounting in CFS of the borrowing costs associated with the term loan
23 Guidance on consolidation procedures for indirect subsidiaries
30 Assessment of control1 when an investor has potential voting rights (Similar to ITFG 3, Issue 5)
Guidance on intragroup elimination in CFS when a parent and its subsidiary have different
31
reporting period end
Classification of current/non-current in CFS when parent and its subsidiary have different
32
reporting dates
Guidance on alignment in case of differences in of current/non-current classification with re-
33
spect to Ind AS vis-à-vis IFRS
Accounting of transaction cost incurred to acquire outstanding part of NCI (wholly or partially) or
34
sell (without loss of control)
Accounting for changes in a parent’s ownership interest in a subsidiary (not resulting in the loss
35
of control) (Similar to ITFG 13, Issue 7)
36 Accounting impact on NCI of interest free loan given to subsidiary without repayment condition
Guidance on apportionment of profit or loss between parent and NCI in case of change in
37
proportion of the equity held by NCI
38 Accounting treatment on loss of control of the subsidiary in the CFS (Similar to ITFG 17, Issue 5)
Guidance on accounting of an investment entity as per Ind AS 110 that provides investment
39 management services
(Similar to ITFG 20, Issue 2)
Guidance on accounting for an investment entity as per Ind AS 110 (with an option to buy
40
investments in subsidiary)
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13
Assessment of joint control when one of the party to the joint arrangement has an option to buy
8 other party’s shareholding at any time in the event of disagreement on any decision relating to
relevant activities of the joint arrangement
Accounting treatment of a joint arrangement where certain parties have joint control while oth-
17
ers account for it as a joint operation.
The accounting on intragroup balances in the separate and consolidated financial statements of
18
a joint operator
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Ind AS Implementation Guide I 14
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15
2. Business combinations
(including common control
transactions)
Summary
This chapter covers:
• Ind AS 103, Business Combinations
Certain business combinations such as mergers and amalgamations are dealt with under
Chapter XV-Compromises, Arrangements and Amalgamations of the Companies Act, 2013 (2013
Act). With the notification of the relevant sections dealing with compromises, arrangements and
amalgamations (including fast track amalgamations and demergers), companies are required to
make an application to the National Company Law Tribunal (NCLT) in case of such schemes.
Key principles
General principles
• Ind AS 103 provides guidance on accounting for – Acquisition of an asset or group of assets that
business combinations under the acquisition does not constitute a business
method. A business combination is a transaction or
– Acquisition of an investment in a subsidiary that
other event in which a reporting entity (the acquirer)
is required to be measured at Fair Value through
obtains control of one or more businesses (the
Profit or Loss (FVTPL) by an investment entity.
acquiree). The date of acquisition is the date on
which the acquirer obtains control of the acquiree. • A ‘business’ is an integrated set of activities and
assets that are capable of being conducted and
• There are certain exceptions to acquisition
managed to provide a return to investors by way of
accounting:
dividends, lower costs or other economic benefits.
– Formation of a joint arrangement
Ability to
Input Processes
create output
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Ind AS Implementation Guide I 16
Guidance from ITFG clarifications the combining entities are reflected at their carrying
amounts. Accordingly, post-merger, the SFS of the
merged entity would reflect combination of the
Business combination under common carrying amounts of assets and liabilities reflected
control in the SFS of the entities (as appearing in their
Accounting for business combinations of entities respective SFS)
under common control • Situation 2: Merger of subsidiary with its parent:
Under IFRS, there is limited authoritative guidance An entity merges with its parent entity. In such a
on accounting for legal mergers or common control case, nothing changes and the transaction only
business combinations. However, internationally means that the assets, liabilities and reserves of the
practices have developed where it is acceptable subsidiary which were appearing in the CFS of the
to choose an accounting policy (to be applied group immediately before the merger, would now
consistently) to determine values of assets and be a part of the SFS of the merged parent entity.
liabilities of the acquiree entity. The acquirer in a The SFS of the parent entity (to the extent of such
common control transaction can use either of the a common control transaction) would be considered
following in its CFS: as a continuation of the consolidated group.
Accordingly, it would be appropriate to recognise
• Book value (carry-over basis) accounting on the
the carrying value of assets, liabilities and reserves
basis that the investment has simply been moved pertaining to the combining subsidiary, as appearing
from one part of the group to another, or in the CFS of the parent entity. (ITFG 9, Issue 2)
• IFRS 3 accounting on the basis that the acquirer is
a separate entity in its own right and should not be Restatement of financial statements
confused with the economic group as a whole.
The ITFG considered two situations with respect The pooling of interest method requires that the
to common control transactions and provided financial information in the financial statements
clarifications as below: in respect of prior periods should be restated as if
• Situation 1: Merger of two fellow subsidiaries: An the business combination had occurred from the
entity merges with its fellow subsidiary (i.e. another beginning of the preceding period.
entity with the same parent entity). Appendix C of
Ind AS 103 provides that the assets and liabilities of
A Ltd.
B Ltd. C Ltd.
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Ind AS Implementation Guide I 18
Situation 2: ITFG assumed that division transferred In the given case, ITFG noted that there is only a
from A Ltd to C Ltd. constitutes a transfer of business change in composition of the reporting entity and it is
under Ind AS 103. The transfer would be qualified as not retrospective application of an accounting policy or
a common control business combination transaction retrospective restatement/reclassification.
from the perspective of C Ltd. on the basis the Accordingly, PQR Ltd would be required only to
following analysis: restate financial statements for the year ended 31
• C Ltd obtains control of a business that it did not March 2019 with comparative information for 31
previously control March 2018. A third balance sheet as at 1 April 2017 is
• Both the combining parties, i.e., C Ltd. (the not required to be presented. (ITFG 22 Issue 5)
acquirer) and the division transferred, are controlled Requirement to restate in case of common control
by A Ltd. before and after the transfer. merger
• Control of A Ltd. over the transferee (C Ltd.) and the Two entities B Ltd. and C Ltd. (both under common
transferor (the transferred division) cannot be said control of another entity A Ltd.) filed a scheme of
to be transitory since C Ltd. has been a subsidiary arrangement with NCLT in the year 2017. As per the
of A Ltd. since January 2016 scheme, one of the business divisions of B Ltd. was
Since the transfer qualifies as common control to be demerged and merged with C Ltd. The scheme
business combination, C Ltd. would be required to was approved by the NCLT in June 2019 (i.e. before
account for the transfer of the division in its financial the approval by the Board of Directors of the financial
statements by applying the pooling of interests statements for the year ended 31 March 2019).
method as per Appendix C to Ind AS 103. The appointed date of merger as per the scheme was
Further C Ltd. would be required to prepare 1 April 2018. Both the entities are required to prepare
its financial statements (including comparative their first Ind AS financial statements for year ended
information) for the year ended 31 March 2019 as 31 March 2018.
if the transfer of the division had occurred from the In this situation, ITFG considered and clarified on the
beginning of the comparative period presented in the following two issues:
financial statements for the year ended 31 March 1. Whether the financials of C Ltd. for the financial
2019 i.e., 1 April 2017, and not the appointed date of 1 year 2017-18 should be restated considering that
October 2018 specified in the scheme. (ITFG 19, Issue the appointed date of the merger is 1 April 2018
5)
The ITFG clarified that as per requirements of Ind
Restatement of comparative information in case of AS 103, C Ltd. would be required to restate financial
common control business combination statements for the year ended 31 March 2019
A company ABC Ltd. merges into PQR Ltd (common with comparative information for 31 March 2018
control business combination). The order of NCLT (financial year 2017-18) regardless of appointed date
approving the scheme of merger was received on 27 as 1 April 2018.
March 2019 (appointed date for the merger is 1 April 2. Whether the financials of B (demerged entity) for
2016). PQR Ltd has been applying Ind AS with effect the financial year 2017-18 should be restated
from financial year beginning 1 April 2016 (transition
The issue under consideration is with regard
date is 1 April 2015).
to applicability of Appendix C of Ind AS 103 to
The issue under consideration is while preparing the demerged entity (i.e. transferor in the given case)
financial statements for the year ended 31 March with respect to restatement of comparative
2019, whether reinstatement of comparatives is information. Appendix C of Ind AS 103 requires
required only for 31 March 2018 or whether a third accounting for a common control business
balance sheet as of 1 April 2017 is also required to be combination only from the perspective of the
presented. transferee.
The ITFG clarified that Appendix C of Ind AS 103 Accordingly, ITFG clarified restatement of
requires only restatement of comparative information comparative information applies only to the
and does not require a third balance sheet at the transferee (i.e. C Ltd.) and not the transferor (i.e.
beginning of the preceding period. B Ltd.). However, B Ltd.is required to evaluate
Ind AS 1 requires third balance sheet as at the any disclosure to be made in consonance with
beginning of the preceding period when an entity Ind AS 105, Non-current Assets Held for Sale and
applies an accounting policy retrospectively or makes Discontinued Operations. (ITFG 22, Issue 6)
retrospective restatement of items or reclassifies
items in its financial statements.
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19
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Ind AS Implementation Guide I 20
Demerger of one of the businesses of parent to its • Scenario B: Accounting treatment of demerger
subsidiary and court approved scheme prescribed in the court-approved scheme: The
In a given case, a parent P demerged one of its ICAI had made an announcement which provides
businesses under the order of the High Court and that the accounting treatment of a transaction as
sold it to its subsidiary S in financial year 2016-17. required under an order of a court or tribunal (or
Both P and S are covered in phase II of the Ind AS other similar authority) overrides the accounting
implementation road map. S acquired the assets and treatment that would otherwise be required to be
liabilities of the demerged business at their fair values followed in respect of the transaction. Therefore, it
and issued its consideration (calculated on the basis of is mandatory for the respective company to follow
the fair value of the business of P) (as required under the treatment as per the order of the court/tribunal.
the previous GAAP). The acquisition of business by Accordingly, in the given case, if the court approved
S from P is a common control business combination scheme of demerger prescribed the accounting
within the meaning of Appendix C to Ind AS 103 (since treatment for the demerger in the books of
S is covered under the Ind AS road map and needs to company A (for instance, recognition of assets and
apply Ind AS 103 on the date of transition). liabilities acquired at their respective fair values as
An issue arose whether S was required to apply Ind at the date of demerger), then company A would
AS 103 on the acquisition of business from P. be required to follow the treatment prescribed
in the scheme in its financial statements for the
In this case, the demerger of one of the business of P
financial year 2016-17. Further, if the effect of such
occurred in financial year 2016-17 and in that year Ind
accounting treatment has to be carried over in
AS was not applicable to either P or S. Therefore, S
subsequent years, then also the same treatment of
accounted for the assets and liabilities acquired under
court approved scheme would be followed in the
previous GAAP at their respective fair values as at the
subsequent years subject to compliance of auditing
date of demerger.
standards.
Later S had to adopt Ind AS from the financial year
Further, appropriate disclosures should be made in
2017-18 wherein the comparative amounts would be
the financial statements:
presented for financial year 2016-17 under Ind AS. The
above demerger transaction occurred after the date of – A description of the accounting treatment made
transition to Ind AS and would be covered under Ind along with the reason that the same has been
AS 101. adopted because of the court/NCLT order
The following two scenarios were considered for the – Description of the difference between the
given case: accounting treatment prescribed in the AS and
• Scenario A: Accounting treatment of demerger not that followed by the company
prescribed in the court-approved scheme: In this – The financial impact, if any, arising due to such a
case, the court approved scheme did not prescribe difference.
any accounting treatment for the demerger in the
books of S. As the demerger occurred after the Therefore, in the present case it was concluded that
date of transition to Ind AS by S, the demerger the subsidiary S would be required to follow the
transaction would qualify as a common control accounting requirements of Ind AS which were not in
business combination. Therefore, S would be conflict with the provisions of the court scheme. (ITFG
required to account for the demerger as per 16, Issue 5)
Appendix C to Ind AS 103 i.e. under ‘pooling of
interest method’ in the financial statements for the
financial year 2016-17. Accordingly, S in its financial
statements, would be required to recognise
assets and liabilities acquired from the parent P
at their respective book values (i.e. as appearing
in the books of P). In this case if P and S were
under common control as on 1 April 2016, then
the business combination would be restated from
1 April 2016 irrespective of the actual date of the
business combination. Therefore, while presenting
the comparative amounts in the Ind AS financial
statements for financial year 2017-18, the subsidiary
S would be required to restate the amount of
assets and liabilities recognised under previous
GAAP for financial year 2016-17 following pooling of
interest method.
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Acquisition date in a scheme approved by NCLT • Business combination is not under common
Ind AS 103 requires an acquirer to identify an control: In such a case, Ind AS 103 provides that
acquisition date which is the date on which it obtains the date of acquisition is the date from which an
control of the acquiree. Such a date is generally the acquirer obtains control of the acquiree.
closing date on which the acquirer legally transfers In cases where the auditor is of the view that as per
the consideration, acquires the assets and assumes the proposed accounting treatment, the date from
the liabilities of the acquiree. However, an acquirer which the amalgamation is effected in the books of
could obtain control on a date earlier or later than the accounts of the amalgamated company is different
closing date (e.g. a written agreement provides that from the acquisition date as per the standard
the acquirer obtains control of the acquiree on a date i.e., the date on which control has been actually
before the closing date). An acquirer should consider transferred, then the auditor should state the same
all relevant facts and circumstances in making this in the certificate as required to be issued as per the
assessment. proviso to Section 232(3) of the 2013 Act. However,
In accordance with the provisions of the 2013 Act if the NCLT approves the scheme with a different
(proviso to Section 232(3)), a scheme of arrangement appointed date as compared to the acquisition date
would not be sanctioned by the NCLT unless a as per Ind AS 103, the appointed date as approved
certificate by the company’s auditor has been filed by NCLT under the scheme will be the acquisition
with the NCLT. The certificate should comment on the date. In this situation, the company should provide
effect of the accounting treatment, if any, proposed appropriate disclosures and the auditor should
in the scheme of compromise or arrangement and consider the requirements of relevant auditing
specify whether it is in conformity with the accounting standards. (ITFG 12, Issue 8)
standards prescribed under Section 133 of the 2013
Act. On 21 August 2019, MCA issued a circular
In a situation pursuant to a court scheme, a company and clarified that an appointed date could be a
is merged with another company with an appointed specific calendar date or it could be tied to the
date approved by NCLT. In this case the appointed occurrence of an event, such as grant of license
date was prior to Ind AS implementation date for the by a competent authority or fulfilment of any
company. preconditions agreed upon by the parties, or
Ind AS 103 requires that an entity is first required to meeting any other requirement as agreed upon
assess whether the business combination is under between the parties which are relevant to the
common control. Therefore, the accounting treatment scheme. Accordingly, concerned companies can
would depend on following scenarios: choose and state the agreed appointed date in
the scheme.
• Business combination is under common control:
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Ind AS Implementation Guide I 22
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Ind AS Implementation Guide I 24
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3. Financial instruments
Summary
This chapter covers:
• Ind AS 32, Financial Instruments: Presentation
• Ind AS 107, Financial Instruments: Disclosures
• Ind AS 109, Financial Instruments
Transactions in financial instruments are pervasive across many entities in India. Financial
instruments include financial assets, financial liabilities, equity instruments, compound financial
instruments, etc. Under the Ind AS framework, detailed guidance on recognition, classification,
measurement, presentation and disclosure of financial instruments is available in three Ind AS
(collectively referred to as the ‘FI standards’ in the chapter).
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Ind AS Implementation Guide I 26
Key principles
• Financial instruments that give rise to a contractual • The hedge accounting principles permit excluding
obligation to deliver cash or another financial asset the time value of options, forward element of
are classified as financial liabilities. Instruments that forward contracts, and foreign currency basis
encompass a residual interest in the assets of an spread of currency swaps from the designated
entity after deducting all of its liabilities are classified hedging instrument. These components may be
as equity. Instruments may also have a component separately recognised as a ‘cost of hedging’.
of both - liability and equity, these components will • Financial assets and financial liabilities are required
be classified and presented separately. to be presented on a gross basis. However, an entity
• Puttable instruments are generally classified as may offset these and present them as a net amount
financial liabilities, however, Ind AS 32 specifies the only if it has a legal right, and intends to settle both,
conditions under which these can be considered as the asset and liability simultaneously.
‘equity’. • Adequate disclosure of financial instruments and
• Interest, dividends, losses and gains on financial related risks are imperative to reflect an entity’s
instruments or their components are recorded financial position and performance, the nature and
either in the statement of profit and loss or in Other extent of risks that it is exposed to, and the manner
Comprehensive Income (OCI), depending upon the in which it manages those risks. Accordingly,
classification of the related instrument as financial entities are required to provide quantitative and
liability or equity. qualitative disclosures for exposure to financial
• Financial assets are classified on initial recognition instruments and financial risks, including liquidity
and subsequently measured at amortised cost, Fair risk, credit risk and market risk (which includes
Value Through Profit or Loss (FVTPL) or Fair Value currency risk, interest rate risk and other price risks).
Through Other Comprehensive Income (FVOCI),
depending upon the business model within which Significant differences from IFRS1
they are held and the contractual cash flows of the
instrument (i.e. whether the contractual cash flows Ind AS 32 compared with IAS 32, Financial
are solely in the nature of principal and interest on Instruments: Presentation
the principal amount outstanding).
• IFRS requires an equity conversion option that
• Financial assets measured at amortised cost and is embedded in a foreign currency convertible
at FVOCI are assessed for impairment at each bond, to be recognised as a financial liability
reporting date, using an Expected Credit Loss (ECL) at inception as the conversion price is fixed in
model. foreign currency and not in the entity’s functional
• A modification in the terms of financial instruments currency. Hence, it does not result in an exchange
may result in their derecognition. The FI standards of a fixed amount of cash (in the entity’s functional
prescribe accounting for such modifications, and currency) for a fixed number of shares. Therefore,
the conditions that would result in derecognition the conversion option would not be classified as
equity under IFRS. However, Ind AS provides a
• Hybrid contracts may be treated as a single financial
specific exemption in the definition of a financial
instrument measured at FVTPL, or under certain
liability and states that an exchange of a fixed
specified conditions, embedded derivatives may be
number of shares for a fixed amount of cash in
separated from the host contract, and accounted for
any currency would result in a derivative financial
separately.
instrument being classified as equity.
• All derivatives are generally classified as and
measured at FVTPL, with mark-to-market gains and
losses being recognised in the statement of profit
and loss. However, those derivatives that qualify
as hedging instruments and are designated in a
hedging relationship, are treated in accordance with
the hedge accounting principles prescribed by the FI
standards.
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Guidance from ITFG clarifications an understanding between the government and the
potential applicant/entity that on complying with the
stipulated conditions attached to the scheme, the
Ind AS 32 defines a financial instrument as a contract entity would be granted benefits of the scheme. Once
that gives rise to a financial asset of one entity and the entity has complied with the conditions attached
a financial liability or an equity instrument of another to the scheme then it rightfully becomes entitled to
entity. Generally, Ind AS 109 applies to all types of the incentives attached to the scheme. Thus, such an
financial instruments, though, it has certain exceptions incentive receivable would fall within the definition of
as well. financial instrument and accounted for as a financial
asset in accordance with Ind AS 109. (ITFG 15, Issue 3)
Accounting of shares held by a broking
entity for trading on its own account
In practice, evaluation may require the exercise of
significant judgement by entities that are entitled
Investments in shares of other entities’ meet the to receive incentives from the government, in
definition of financial instruments. Accordingly, order to determine whether a ‘contractual’ right
these would be recognised and measured in exists resulting in the recognition of a financial
accordance with Ind AS 109, presented as per the asset. This interpretation may affect accounting
requirements of Ind AS 32 and disclosed as per of various types of government grants.
the principles enunciated in Ind AS 107.
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Ind AS Implementation Guide I 28
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Ind AS Implementation Guide I 30
Therefore, if no fee has been paid to the director Accordingly, the accounting in SFS would be as
(or other related party), and such party is not being follows:
compensated in any other manner, the company is • If the investment in a subsidiary has been
not required to account for such a financial guarantee accounted for at cost: Credit the distribution
in its financial statements considering that the unit of received to the statement of profit and loss.
account is the guaranteed loan. The loan is recognised Impairment loss, if any, would be separately
at its fair value that is expected to be the face value of considered.
the loan proceeds received by the company. However,
this transaction needs to be evaluated for disclosure • If the investment in subsidiary has been
under Ind AS 24, Related Party Disclosures which accounted for in accordance with Ind AS 109
requires disclosure of any guarantees given to or then accounting depends upon whether its
received from related parties. (ITFG 13, Issue 2) FVOCI or FVTPL as below:
– Measured at FVOCI: Recognise distribution in
the statement of profit and loss in accordance
A similar scenario may involve a parent entity
with guidance in Appendix B to Ind AS 109,
providing a financial guarantee to a bank relating
unless the distribution clearly represents a
to a loan advanced to its subsidiary. While Ind AS
recovery of part of the cost of the investment.
109 requires the guarantor, the parent entity to
recognise the guarantee liability at its fair value, – Measured at FVTPL: Credit the distribution
there is no specific accounting guidance relating received to the statement of profit and loss.
to a situation where a subsidiary does not pay Further, in accordance with Ind AS 24, in this situation
any guarantee fee or premium to the parent too, disclosures of related party transactions during
entity. In this case, we consider that this is akin the periods covered by the financial instruments,
to a deemed capital contribution by the parent including details of any guarantees given or received
to its subsidiary and should be recognised as an by the entity are required to be made. Based on this,
additional investment in the subsidiary. the parent would be required to make necessary
Additionally, ITFG has clarified the treatment for disclosure of the financial guarantee provided by its
such a case as above. subsidiary. (ITFG 16, Issue 1)
Financial guarantee by a parent for a loan taken
by its subsidiary that is repaid earlier than the
Where a subsidiary had issued a financial guarantee scheduled term
against a loan taken by its parents, ITFG clarified that
In a case where a financial guarantee was issued by
since the financial guarantee is an integral part of
a parent (P Ltd.) against a loan taken by its subsidiary
the loan taken, the parent should debit the fair value
(S Ltd.). The loan was initially scheduled to be repaid
of the guarantee to the carrying amount of the loan
over a period of 10 years and therefore, a liability (of
(which would have the effect of such fair value being
say INR1,000) was created by the parent which was
included in determination of Effective Interest Rate
to be amortised over a period of 10 years. When the
(EIR) on the loan) and credit the same in accordance
loan was prepaid within six years, ITFG clarified that
with the requirements of Ind AS 27 (as it is deemed as
guidance provided in Ind AS 8, Accounting Policies,
distribution made by the subsidiary).
Changes in Accounting Estimates and Errors should be
considered to account for the change in the estimate
In accordance with requirements of Ind AS 27, of expected life of the loan.
investment in a subsidiary should be accounted
for at cost or in accordance with Ind AS 109 in the
SFS of the parent.
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Ind AS Implementation Guide I 32
Classification as debt or equity a. The terms of the instrument provide it with the
ability to avoid making cash payment (of the
The primary factor determining the classification dividend as well as of the principal), and convert
of a financial instrument either as a financial the instrument into a fixed number of its own
liability or equity, is whether the entity that shares at any time,
has issued the instrument, has a contractual b. The conversion option is already considered
obligation to make payments (either principal, in determining the classification of the entire
interest/dividend or both) or has a contractual instrument, and hence is not accounted for
right to avoid making such payment. separately as an embedded derivative and
c. Discretionary payment features (such as
discretionary dividend) on equity instruments
are considered as an integral component of the
Discretionary dividends paid on a compound instrument. Considering these facts, the entire
financial instrument, i.e. an instrument that is instrument would be classified as equity in the
partly equity in nature may relate to the equity SFS of S.
component of the instrument. In this scenario,
an entity needs to assess whether discretionary – In the SFS of H: Ind AS 27 provides entities
dividend should be presented in equity. with an accounting policy choice to account for
Depending upon the facts and circumstances in their investments in subsidiaries, joint ventures
certain situations, discretionary dividends could and associates in their SFS, either at cost or in
be presented in profit or loss because dividend accordance with Ind AS 109. Assuming that H
payments on an instrument wholly recognised as has not chosen to account for its investment in
a liability are recognised as an expense. accordance with Ind AS 109, it would account for it
at cost.
– In the CFS: These transactions, being intra-group
In the context of debt-equity classification, the transactions, would be eliminated in accordance
ITFG considered the accounting for the following with Ind AS 110. (ITFG 14, Issue 7)
instruments: Foreign Currency Convertible Bonds (FCCB): In
• Non-cumulative, optionally convertible preference another situation, an entity (PQR) had issued
share issued by a entity (S) to its holding entity (H). FCCBs prior to transition to Ind AS at an interest
rate of six per cent per annum, payable on a half
yearly basis for a period of five years and one day.
These FCCBs would mature post transition to Ind
AS since PQR was required to comply with Ind AS
Issues
from 1 April 2017. The holder of the instruments
Non-cumulative had an option to convert them into fixed number of
optionally convertible shares of PQR.
S H
preference shares A borrowing in the same currency, with a similar
time period and credit status, but without the
As per the terms of issue, S has the option to convert conversion option would have carried an interest
or redeem the stated preference shares. Assuming rate of seven and a half per cent per annum.
that S has an option to convert the preference shares
into a fixed number of its own shares, and dividend
From the perspective of the issuer, the FCCB
payment is discretionary, the accounting for the
had both a liability and an equity component.
instrument will be as follows:
The liability component comprised a contractual
– In the SFS of S: While assessing the classification obligation of PQR to deliver cash to the holder,
of the preference shares in its SFS, S assesses that: and the equity component comprised the
holder’s equity conversion option embedded in
the FCCB to acquire a fixed number of entity’s
own equity instruments. Although the FCCB
was denominated in a foreign currency, the
conversion option would meet the definition of an
equity instrument based on the guidance in Ind
AS 32.
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PQR would be required to split the FCCB into a. For each equity share of Class B held, the
the liability and the equity components on initial shareholder is entitled to subscribe to 100 equity
recognition and present these separately in the shares of Class A.
balance sheet. (ITFG 15, Issue 1) b. The rights offer price was fixed at:
• Compulsorily Redeemable Non-Cumulative – INR60 per Class A share for Indian shareholders,
Preference Shares (RNCPS): In case RNCPS issued and
by an entity (ABC) with a dividend of six per cent
per annum, redeemable in cash after 10 years. – USD1 per Class A share for overseas
The market rate of interest for similar instruments shareholders.
was four per cent per annum. It was clarified that c. The rights offer was valid for six months.
in accordance with Ind AS 32, the RNCPS are
compound financial instruments, since the payment
Ind AS 32 lays down the principles for the
of dividend to preference shareholders is at the
classification of financial instruments as financial
discretion of the issuer, i.e. ABC. Additionally, it was
assets, financial liabilities or equity instruments
clarified that any discretionary dividends would be
from the issuer’s perspective.
recognised when they are actually declared and paid
and since they relate to the equity component, they
would be disclosed in the statement of changes in The definition of financial liabilities, inter alia, states
equity as a distribution of profit or loss. that a financial liability is any liability that is a derivative
(ITFG 15 Issue 2) that would or may be settled other than by the
• Optionally convertible preference shares with exchange of a fixed amount of cash or another financial
discretionary dividend and an embedded call option: asset for a fixed number of the entity’s own equity
An entity K issued 12 per cent, five year, optionally instruments. For this purpose, rights, options or
convertible preference shares with discretionary warrants to acquire a fixed number of the entity’s own
non-cumulative dividend, at par in its functional equity instruments for a fixed amount of any currency
currency. As per the terms of issue: are equity instruments if the entity offers the rights,
a. The holder of the preference shares had an option options or warrants pro rata to all of its existing owners
to convert them into fixed number of equity of the same class of its own non-derivative equity
shares at the end of five years instruments…’
b. If the conversion option was not exercised, then Considering the above definition, ITFG evaluated the
the preference shares would be redeemed at par terms of the rights issue as below:
c. Throughout the five year period, the holder had an – The rights offer was for acquiring a fixed number of
option to put the preference shares back to entity the entity’s own equity instruments (i.e. for each
K at its par amount6. equity share of Class B held, the shareholder was
entitled to subscribe to 100 equity shares of Class A)
In accordance with Ind AS 32, the initial carrying
amount of the compound financial instrument would – The right exercise price was a fixed amount - i.e.
be allocated to its equity and liability components. INR60 per share for Indian shareholders and USD1
(ITFG 17, Issue 9) per share for overseas shareholders
For a discussion on the measurement of above – Entity X had made the rights offer to all the existing
compound financial instruments, please refer the shareholders of Class B equity shares pro-rata to
section on ‘Measurement of compound financial their holding of Class B equity shares.
instrument’. On the basis of the above evaluation, since all the
• Issue of rights offer: An entity X, with INR as conditions for equity classification were met, ITFG
its functional currency had two classes of non - concluded, that the rights offer to Class B shareholders
puttable equity shares - Class A and Class B. Post to acquire Class A shares should be classified as an
the date of transition to Ind AS, entity X made a equity instrument. (ITFG 17, Issue 10)
rights offer to all holders of Class B equity shares.
The terms of the right offer were:
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Ind AS Implementation Guide I 34
7. IAS 32 does not have this exception and conversion option denominated
in a foreign currency does not meet the ‘fixed amount of cash’ criterion.
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Ind AS Implementation Guide I 36
Therefore, in accordance with the above, the whole On initial recognition, a financial asset or a financial
price of the preference shares would be allocated liability is measured at fair value plus or minus directly
to the liability component and no amount would be attributable transaction costs, unless:
assigned to the equity component. (ITFG 17, Issue 9) • The instrument is classified as at FVTPL, in which
case transaction costs are not included, or
On initial recognition, Ind AS 109 requires entities • The instrument is a trade receivable that is initially
to classify financial assets into the amortised measured at the transaction price as defined in Ind
cost, FVOCI or at FVTPL categories based on the AS 115.
business model within which they are held and Normally, the fair value on initial recognition is the
the nature of their contractual cash flows. transaction price as described in Ind AS 109 i.e. the
fair value of the consideration given or received for the
financial instrument. If part of the consideration given
Classification of financial assets or received is for something in addition to the financial
The classification determines the basis on which such instrument, then the entity separately measures the
financial assets are subsequently measured. Entities fair value of the financial instrument in accordance
may hold financial assets within a business model, with Ind AS 113.
which has an objective to either: Low interest and interest free financial instruments8
• Hold assets in order to collect contractual cash An entity may sometimes receive or give certain
flows (‘held to collect’) interest-free or low interest financial instruments, e.g.
• Both collect contractual cash flows and sell financial inter company loans, government loans, interest-free
assets (‘held to collect and for sale’), or security deposits, etc., the transaction price of which
may not necessarily reflect an instrument’s fair value.
• Hold assets for sale (‘held for sale’).
In such a case, the fair value of the instrument is
Financial assets held within a ‘held to collect’ business computed in accordance with Ind AS 113.
model are generally managed by collecting the cash
Ind AS 113 requires entities to maximise the use of
flows generated by the asset over its life. However,
quoted prices or other relevant observable inputs.
Ind AS 109 clarifies that entities need not hold all
However, if these are not available, a valuation
instruments until maturity. Thus, it becomes necessary
technique may also be used, such as a present value
to consider the frequency, value and timing of sales
technique with inputs that include future cash flows
in prior periods, and expectations about future sales
and discount rates that reflect assumption that
activities when assessing the business model. In this
market participants would apply in pricing the financial
context, Ind AS 109 states that sales of instruments
instrument. The difference between the fair value
could be consistent with a ‘held to collect’ business
of the instrument and the transaction price on initial
model if they are infrequent (though significant in
recognition of the instrument would be accounted for
value) or are insignificant in value both individually and
separately. The accounting treatment for these will
in aggregate (even if frequent). Ind AS 109, however,
depend upon the nature of the element included in the
does not define ‘infrequent’ or ‘insignificant’.
instrument.
8. EAC- January 2019 edition of the ICAI Journal ‘The Chartered Accountant’
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Ind AS Implementation Guide I 38
Dividends on financial liabilities At the date of transition, the amortised cost of the
As per Ind AS 32, dividends paid on financial preference shares (which includes unpaid dividend)
instruments that are classified as financial liabilities, would be computed retrospectively from the date of
would be presented as ‘interest expense’, and their issue using the EIR method (Ind AS 101 does
accounted for accordingly. not provide any mandatory exception or optional
exemptions for such financial instrument).
Ind AS 10, Events after the Reporting Period states that
when entities declare dividends to holders of equity While computing the amortised cost of the preference
instruments after the reporting period, they should not shares using the EIR method, the dividends that have
recognise a liability for those dividends at the end of accrued but not paid would be reflected in the carrying
the reporting period. amount of the liability.
Dividend/interest on financial instruments or In accordance with Ind AS 101, the difference between
components classified as liabilities are ‘interest the amortised cost and the carrying amount of the
expenses’, and hence, should accrue at the end of the preference shares as per the previous GAAP would be
reporting period, irrespective of when the dividend adjusted directly in retained earnings (or, if appropriate,
is declared (even after the reporting period) or paid. If another category of equity) as at the date of transition.
the liability is classified and subsequently measured Further, dividend for periods after the date of transition
at amortised cost, the dividend/interest would be would be accrued in each period, in the same manner
computed using the EIR method and debited to as interest, and if unpaid would get reflected in the
interest expense (in the statement of profit and loss). amortised cost as at the end of the period.
(ITFG 7, Issue 6) (ITFG 20, Issue 3)
Accounting for accumulated arrears of dividend on
cumulative preference shares on transition to Ind When an instrument is classified as a financial
AS liability, all coupon payments are recognised as
A loss-making entity (P) issued cumulative preference part of finance costs in the statement of profit
shares prior to transition to Ind AS. Other facts are as and loss under the EIR method10.
below:
– It did not pay dividend to its preference In the above case, if the dividends were discretionary,
shareholders then the issuer considers whether unpaid dividends
– The accumulated arrears of cumulative preference are added to the redemption amount of the preference
dividend were disclosed as ‘contingent liability’ in shares. If any unpaid dividends are added to the
the notes to the financial statements redemption amount and the entity does not have
the unconditional ability to avoid redemption before
– On transition to Ind AS, the preference shares liquidation, then the dividends are not in substance
were classified as financial liability in accordance discretionary and the entire instrument including the
with the principles of Ind AS 32. discretionary dividend feature is a financial liability.
ITFG clarified that preference shares that are classified Furthermore, if an entity is or may be obliged to
in entirety as a financial liability are accounted for redeem the instrument at fair value, then unpaid
under Ind AS 109 in the same manner as a redeemable dividends are implicitly added to the redemption
debenture or a typical loan. This implies, inter alia, that amount if the payment of dividends decreases the fair
the dividends on the preference shares are accrued in value of the instrument being redeemed.
the same manner as interest on debentures or loans. Also, an entity should evaluate implication on
In the given situation, the preference shares would Minimum Alternate Tax (MAT) computation under the
be classified as financial liability in their entirety (the Income-Tax Act, 1961 (IT Act) with regard to dividend
covenants of their terms of issue relating to dividends on preference shares.
would represent a contractual obligation of P to
pay such dividends). Accordingly, these dividends
would be accrued in the same manner as interest on
debentures or loans. 10. EIR is the rate that exactly discounts estimated future cash
payments or receipts through the expected life of the financial asset/
liability. It is used to compute the gross carrying amount of financial
assets or the amortised cost of financial liabilities.
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Ind AS Implementation Guide I 40
ITFG has also provided further clarification for a and processing fees) are treated as an adjustment to
financial asset while classifying under amortised cost the EIR and are amortised over the expected life of the
and FVOCI (debt) categories. instrument.
Therefore, in accordance with Ind AS 109, to be (Please refer chapter 10 on Other topics- Borrowing
classified as amortised cost or FVOCI (debt) category, Costs for more details on capitalisation of DDT paid on
a financial asset must meet the following two preference shares dividend and processing charges to
conditions: the cost of qualifying asset) (ITFG 13, Issue 1 and ITFG
• Business Model Test and 14, Issue 1)
• Contractual Cash flow Characteristic test (SPPI test). Undisbursed loans
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41
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Ind AS Implementation Guide I 42
fee. Instead, these are an integral part of originating • Change of lender results in legal release
the new loan and would be considered as a from primary liability: It should derecognise
transaction cost that is included in the computation entire amount of the existing loan and the new
of EIR of the new loan. (ITFG 12, Issue 4) arrangement with ARC would be accounted for as
a new loan. The difference between the carrying
It is imperative to note that modification of amount of the financial liability extinguished and
accounting treatment (described above) may the consideration paid (including any non-cash
not apply to situations where the contractual assets transferred or liabilities assumed) would be
terms of a loan are modified/restructured due recognised in the statement of profit and loss.
to financial difficulties. Entities would have to • Change of lender does not result in legal release
analyse the relevant facts and circumstances from primary liability: It should consider whether
to determine whether the modified loan should there is a substantial modification of terms of the
be derecognised and the consequent impact existing financial liability (or part of it) based on the
on costs and fees incurred in relation to the quantitative and qualitative assessment.
origination or modification of the loan.
• In this case, ITFG highlighted that there were
no additional factors that would require B Ltd. to
Restructuring of loan perform a qualitative analysis. Therefore, if the
quantitative threshold of 10 per cent is met, then
Where a non-performing loan was transferred to modification of terms should be considered to be
an Asset Reconstruction Company (ARC) and was substantial and vice-versa.
restructured by the ARC, the borrower (say B Ltd.)
was required to assess whether this would lead to • In this case, a part of the loan had been settled by
derecognition of the existing loan. The restructuring way of issue of equity shares of B Ltd. Therefore,
involved: fair value of the equity shares should be accounted
for in accordance with Appendix D, Extinguishing
• A hair cut by ARC for some portion of the loan Financial Liabilities with Equity Instruments to Ind
• Partial settlement of the loan by issue of fully paid- AS 109 and guidance contained in Ind AS 109. With
up equity shares at traded market price and respect to the balance portion, the modifications
• The balance loan amount would be paid in relate to terms that were captured by the
installments over seven years at a revised interest quantitative test (i.e. the haircut, rescheduling of
rate, which was linked to the Marginal Cost of repayment, and change in interest rate). Accordingly,
funds-based Lending Rate (MCLR). if the modification of balance loan was considered
to be substantial, then B Ltd. would be required
to derecognise the balance loan and recognise
The guidance given in Ind AS 109 relating to
the new modified loan. Any difference between
extinguishment of a liability and modification of
the carrying amount of the original loan and new
debt provides that an entity should derecognise
modified loan would be recognised in the statement
a financial liability (or a part of a financial
of profit and loss. (ITFG 16, Issue 3)
liability) from its balance sheet only when it is
extinguished or is substantially modified.
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43
Disclosure
Market risk disclosures for certain instruments
As per Ind AS 107, entities are required to provide
quantitative and qualitative disclosures of their
exposure to various financial risks arising from financial
instruments. Ind AS 107 also requires disclosure
of an entity’s objectives, policies and processes for
managing those risks and other concentrations of risk.
Additionally, with respect to market risk, in addition
to disclosing the exposure to foreign currency risk,
interest rate risk, and other price risk, an entity is
required to provide an analysis of sensitivity to these
risks. This sensitivity analysis reflects how profit or
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Ind AS Implementation Guide I 44
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45
EAC opinions facility as this cost would not have been incurred if the
entity had not incurred the loan liability.
Expected Credit Loss (ECL) on the Thus, the financial guarantee fee paid (initially as well
as subsequently) by the entity should be considered
amount due in the course of business for computation of EIR while measuring the loan
from government organisations12 liability at amortised cost in compliance with the
Ind AS 109 provides guidance for impairment provisions of Ind AS 109.
recognition of ECL on financial instruments.
Further, the use of practical expedients when Treatment of financial liability under Ind
measuring ECL, if they are consistent with the AS 32 and Ind AS 10914
principles provided therein, is permitted by Ind AS Please refer to similar guidance discussed in the
109. chapter in earlier section on ‘Low interest and interest
EAC considered a situation in which A Ltd. (a free financial instruments’.
government entity) is mainly engaged in business
Treatment of ‘prepayment penalty’
with central government, state government,
autonomous bodies or public sector undertakings. incurred for foreclosure of existing loan
In accordance with Ind AS 109, A Ltd. applies
and availing new loan borrowings15
ECL model for measurement and recognition of The EAC deliberated on the accounting treatment of
impairment loss for financial assets. the ‘prepayment penalty’ incurred for foreclosure of an
existing loan and availing new loan/borrowing
As a practical expedient A Ltd. has adopted
(from a new bank).
‘simplified approach’ using the provision matrix
method for recognition of expected loss on its Transaction costs are the incremental costs which are
trade receivables. directly attributable to the acquisition or disposal of a
financial liability.
EAC deliberated on whether Ind AS 109 provides
an exemption from application of ECL model. Ind AS 109 requires that at the time of initial
recognition, financial liability should include only the
The EAC concluded that the impairment
transaction costs that are directly attributable to the
requirements of Ind AS 109 are mandatory and
acquisition or issue of the new financial liability and not
there are no exceptions. Trade receivables are
the transaction cost of disposal of the existing financial
measured at amortised cost then they are subject
liability.
to the impairment requirements of Ind AS 109.
In this case, EAC clarified that prepayment penalty is
Computation of EIR on borrowings13 the transaction cost of disposal of the existing financial
The EAC deliberated on the issue related liability (loan) which is payable to the existing loan
to accounting for guarantee fee paid to the provider rather than the incremental cost of acquisition
Government of India in relation to the loan taken or issue of the new financial liability (new loan) from
from the foreign lender (since Government of India a new bank. Further, such a penalty is incurred to
is not directly a party/lender in given situation). extinguish the existing liability and to get the benefits
of a lower cost liability (loan). It is not incurred to
Ind AS 109 requires that the fees paid or received
acquire a new financial liability (loan). Therefore, this
between parties to the contract that are an
penalty could not be treated as directly attributable
integral part of the EIR and transaction costs are to
to the acquisition of the new financial liability and
be considered while applying EIR method.
should be recognised as part of the gain or loss on
Ind AS 109 further provides that transaction costs extinguishment/derecognition of the old loan in the
are incremental costs that are directly attributable statement of profit and loss.
to the acquisition or issue of a financial liability and
an incremental cost is one that would not have
been incurred if the entity had not acquired or 12. EAC-October 2018 edition of the ICAI Journal ‘The Chartered
Accountant’
issued the financial instrument.
13. EAC-August 2019 edition of the ICAI Journal, ‘The Chartered Accountant’
Accordingly, in the above situation, the EAC 14. EAC- January 2019 edition of the ICAI Journal ‘The Chartered
clarified, the guarantee fee paid (initially as well Accountant’
as subsequently) is an incremental cost which is 15. EAC- January 2019 edition of the ICAI Journal ‘The Chartered
directly attributable to the acquisition of the loan Accountant’
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Ind AS Implementation Guide I 46
Accounting for Funded Interest Term • Where B Ltd. was acting in its capacity of a
Loan (FITL) subsequent to restructuring shareholder (by providing financial support
in the form of interest-free funding): The
of a loan taken from a shareholder16 difference between the nominal amount and the
Due to financial difficulties, an entity restructured its fair value on initial recognition of the FITL would
loan and availed a Funded Interest Term Loan (FITL). be recognised in an appropriate component of
As a result of restructuring agreement, the equity (as a non-reciprocal capital contribution by
repayment terms of the original loans were the shareholder) on transition to Ind AS (Similar to
extended and the interest accrued thereon was guidance of ITFG 18, Issue 3)
converted into another loan called FITL. Further, • Where B Ltd. was acting as a lender (similar
the entity under the previous Indian GAAP, to an unrelated lender by providing financial
derecognised the interest accrued and recognised restructuring package to its borrower due to
FITL as an unsecured term loan under financial difficulty): The difference between the
‘long-term borrowings’ in its financial statements. FITL amount and its fair value would generally be
Ind AS 109 requires an entity to assess whether recognised in profit or loss, unless it qualifies for
the modification in the terms of the borrowings recognition as an asset or liability.
would result in its derecognition and the recognition Government grant
of a new liability. Further, Ind AS 101 prohibits
retrospective application of the derecognition If the lender is government entity then it needs to
requirement (where such derecognition was prior be evaluated if the lender is acting in its capacity of
to transition to Ind AS), unless the information a government.
required to apply the same was obtained at the time Ind AS 20, Accounting for Government Grants and
of initially accounting for those transactions. Disclosure of Government Assistance, provides
Assuming that the entity in this case did not have that the government grants are assistance by
the information required to apply the derecognition government in the form of transfers of resources to
requirements retrospectively, in accordance with an entity in return for past or future compliance with
Ind AS 101, the entity should not reassess whether certain conditions relating to the operating activities
the derecognition of accrued interest on the old of the entity.
loans and recognition of the new loans (including The FITL is an interest-free loan extended by the
the FITL) would have been appropriate under Ind AS. lender to the entity as a consequence of a financial
Accounting for interest-free loan restructuring package due to financial difficulty. The
interest-free benefit is, therefore, not in the nature
Since the FITL is an interest-free loan (the EAC of government assistance or benefits provided
noted), entity would have to determine its fair value to similar entities in general. There are no further
on initial recognition (i.e., at the time of the financial terms or conditions attached to the receipt of this
restructuring), being its discounted present value benefit that need to be complied with by the entity.
based on the prevailing market interest rate (for These factors indicate that the lender is not acting in
a similar instrument as to currency, term, type of its capacity as government in providing the interest-
interest rate and other factors with a similar credit free FITL to the entity.
rating) at the time of initial recognition.
Hence, the EAC clarified that the FITL does not
Additionally, the EAC clarified that the amortised meet the definition of a government grant.
cost on the date of transition would then be
determined by unwinding the discount for the
period from the date of initial recognition to the 16. EAC-March 2019 edition of the ICAI Journal ‘The Chartered
transition date. The resultant adjustment, related Accountant’
to the unwinding of the discount, should be
recognised in retained earnings on transition.
In the given situation the entity would be required to
determine whether B Ltd. (while providing the loan)
was acting as a shareholder or a lender. Thereafter
the accounting treatment would be as below:
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4. Tangibles and
Intangibles Assets
Summary
This chapter covers:
• Ind AS 16, Property, Plant and Equipment
• Ind AS 38, Intangible Assets
• Ind AS 40, Investment Property
Non-financial assets recognised by an entity under Ind AS may include, tangible fixed assets
such as Property, Plant and Equipment (PPE), investment property and intangible assets such
as technology, brands, etc. This chapter includes a discussion on key clarifications on the
implementation issues on applying the standards on non-financial assets.
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Ind AS Implementation Guide I 50
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Other clarifications
Revenue-based amortisation
Ind AS 38 requires the amortisation method used for
intangible assets with a finite useful life to reflect the
pattern in which an asset’s future economic benefits
are expected to be consumed by an entity. There is a
rebuttable presumption that an amortisation method
based on revenue generated based on the use of
an intangible asset is inappropriate except in limited
circumstances. Generally, intangible assets with a
finite useful life are amortised on a straight-line basis
over their useful life.
Paragraph 7AA of Ind AS 38 read with paragraph D22
of Ind AS 101 specifically permits revenue-based
amortisation for intangible assets arising from service
concession arrangements in respect of toll roads
recognised in the financial statements for the period
ending immediately before the beginning of the first Accounting for mining lease rights as intangible
Ind AS reporting period. This method of amortisation is assets after demonstration of technical feasibility
not generally permitted for intangible assets related to and commercial viability of extracting a mineral
toll roads that are recognised subsequently. resource
Earlier Schedule II to the 2013 Act, permitted Both Ind AS 16, Property, Plant and Equipment and Ind
revenue- based amortisation for such intangible asset AS 116, Leases exclude from their respective scopes
without any reference to any financial year. This was the accounting for mining for extraction of lime stone
inconsistent with the guidance in Ind AS 101. or similar such resources.
(ITFG 3, Issue 13)
Accounting guidance related to exploration for and
evaluation of mineral resources is provided in Ind
The Schedule II to the 2013 Act was amended AS 106, Exploration for and Evaluation of Mineral
by MCA on 9 December 2016 to clarify that Ind Resources. However, Ind AS 106 also does not apply
AS entities would be unable to apply revenue- after both the following characteristics of extracting a
based amortisation method to toll road related mineral resource are demonstrable:
intangible assets that are recognised after the
• The technical feasibility and
beginning of the first year of adoption of Ind AS.
• Commercial viability.
In the given case, ABC Ltd. is a cement manufacturer.
(Please refer Chapter 9, First-time Adoption of Ind AS
It has entered into a lease agreement with PQR Ltd.
for more details on revenue-based amortisation of toll
for rights for the extraction of lime stone (i.e. principal
roads and application of exemption to toll roads under
raw material for manufacture of cement).
construction)
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Ind AS Implementation Guide I 52
In the current scenario, ITFG considered the following Also, Ind AS 38 recognises that in choosing an
two issues related to extraction of mineral resources appropriate amortisation method, an entity could
(such as limestone), after the establishment of determine the predominant limiting factor that is
technical feasibility and commercial viability of inherent in the intangible asset. For example, the
extracting the mineral resource: contract that sets out the entity’s rights over its use
• Classification of such rights as assets of an intangible asset might specify the entity’s use
of the intangible asset as a predetermined number of
• Amortisation of such rights i.e., whether to be years (i.e. time), as a number of units produced or as a
based on lease term in years (period-based) or fixed total amount of revenue to be generated.
based on
quantity of mineral reserves (quantity based).
Identification of such a predominant limiting
Classification of mineral rights as assets factor could serve as the starting point for
In the current scenario. ITFG considered the following: the identification of the appropriate basis of
amortisation, but another basis may be applied if
• The rights do not relate to a mine in exploration
it more closely reflects the expected pattern of
and evaluation stage but to a mine for which
consumption of economic benefits.
the technical feasibility and commercial viability
of extracting the limestone has already been
determined In accordance with the above guidance, ITFG clarified
• The payment made (or to be made) by the entity that selection of an appropriate amortisation method
for obtaining the mining lease rights is neither for the mining lease requires consideration of the exact
expenditure on ‘development’ nor on ‘extraction’ facts and circumstances of the case. This assessment
of minerals or other non-regenerative resources. would need to be made by the entity itself in the light
of its detailed and in-depth knowledge of the facts and
In view of the above, the ITFG concluded that the
circumstances of its particular case. (ITFG 22, Issue 3)
mining rights under the current scenario would be
classified as intangible assets and accordingly be Applicability of Ind AS 115, Revenue from
accounted for as per Ind AS 38. Contracts with Customers to distribution of gifts
Amortisation of mineral rights In a given case, ABC Ltd. (a pharmaceutical company)
distributed gifts (mobile phones, decorative items and
In accordance with the guidance provided by Ind AS 38,
the like) along with its product catalogues to doctors to
the depreciable amount of an intangible asset with a
encourage them to prescribe medicines manufactured
finite useful life is to be allocated on a systematic basis
by it. No conditions are attached with the items
over its useful life.
distributed.
Further, Ind AS 38 requires that the amortisation
The issue under consideration by ITFG is with regard
method used should reflect the pattern in which the
to application of Ind AS 115 to distribution of gifts to
asset’s future economic benefits are expected to
doctors or whether these are to be treated as part of
be consumed by the entity. If that pattern cannot
sales promotion activities.
be determined reliably, the straight-line method
should be used. Ind AS 38 recognises that a variety The ITFG reiterated the scope of Ind AS 115 among
of amortisation methods could be used to allocate other things to include following:
the depreciable amount of an asset on a systematic
basis over its useful life. These methods include the
following:
• The Straight-Line Method (SLM)
• The diminishing balance method and
• The Units Of Production (UOP) method.
The method used is selected on the basis of the
expected pattern of consumption of the expected
future economic benefits embodied in the asset and Existence Counterparty The goods or
is to be applied consistently from period to period, of contract to the contract services are
unless there is a change in the expected pattern of between the is customer an output of
consumption of those future economic benefits. parties the entity’s
ordinary
activities.
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Ind AS Implementation Guide I 54
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Issue
Topic
number
Guidance on capitalisation of expenditure incurred to obtain regulatory permission to set-up a
1
factory
Guidance on capitalisation of expenditure incurred on enabling assets (such as railway sidings,
roads, bridges) when an entity does not acquire ownership rights and guidance on accounting
2
for their depreciation
(Refer ITFG 2, Issue 5 and ITFG 11, Issue 8)
Guidance on presentation of the enabling assets when an entity does not acquire ownership
3
rights
Guidance on accounting when certain items are expensed as incurred that are below certain
4
threshold determined by the management
Guidance on capitalisation of machinery spares used for ‘more than one period’
5
(Refer ITFG 2, Issue 4)
Guidance on accounting for spares used for ‘more than one period’
6
(Refer ITFG 2, Issue 4)
7 Guidance on accounting for paintings and sculptures held for aesthetic purposes
Guidance on capitalisation of subsequent costs incurred on renovation of food court and gaming
8
zone as PPE or to be expensed in the statement of profit and loss
Guidance on accounting for subsequent overhauling costs incurred on replacement of critical
9
parts and servicing charges thereoff
Guidance on accounting for site preparation costs which are directly attributable to the
10
construction of a new factory
11 Guidance on accounting for production costs incurred during trial runs
Guidance on accounting for costs to be incurred to relocate an existing manufacturing facilities
12
at a temporary site
13 Guidance on accounting for renovation expense prior to commencement of operation
Guidance on whether employee benefit expenses incurred on a project are directly attributable
14 to bringing the asset to the location and condition necessary for it to be capable of operating in
the manner intended by management.
Guidance on whether relocation costs incurred to relocate the residents to another site should
15
be capitalised
Guidance on whether the cost of technical know-how fee related to plant design incurred under
16
the engineering agreement should be capitalised as an intangible asset
Guidance on whether cancellation fees on a contract would be considered directly attributable
17 to bringing the asset to the location and condition necessary for it to be capable of operations in
the manner intended by management
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Ind AS Implementation Guide I 56
Guidance on accounting for acquisition of land with an existing building in the books of accounts
20
of a real estate developer
Guidance on accounting for fixed costs, including abnormal costs incurred during period on
21
interruption
Guidance on whether demurrage should be considered as an element of cost for the purpose of
22
determining the cost of imported plant and machinery
Guidance on allocation of total cost to each significant component of an asset when separate
31
costs are not available
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57
5. Income taxes
Summary
This chapter covers:
• Ind AS 12, Income Taxes
Income taxes include all taxes (domestic and foreign) based on taxable profits. The principal issue
in accounting for income taxes is how to account for the current and future tax consequences of
the following:
• The future recovery (settlement) of the carrying amount of assets (liabilities) that are
recognised in an entity’s balance sheet
• Transactions and other events of the current period that are recognised in an entity’s financial
statements.
Key principles
General principles • Current tax is the amount of income taxes payable
(recoverable) in respect of the taxable profit (tax
• Ind AS 12 includes all domestic and foreign
loss) for a period.
taxes which are based on taxable profits as also
withholding taxes (which are payable by a subsidiary, • Deferred tax liabilities are the amounts of income
associate or joint venture on distributions to taxes payable in future periods in respect of taxable
investors). temporary differences.
• Ind AS 12 requires recognition of tax consequences • Deferred tax assets are the amounts of income
of difference between the carrying amounts of taxes recoverable in future periods in respect of
assets and liabilities and their tax base. deductible temporary differences, carry forward of
unused tax losses and carry forward of unused tax
credits.
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Ind AS Implementation Guide I 58
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Ind AS Implementation Guide I 60
Creation of deferred taxes on land converted in The issue considered was whether Z Ltd. recognise
inventory deferred tax on land on the date of transition to Ind AS.
The ITFG discussed the conversion of a capital asset In accordance with guidance provided in Ind AS 12, the
into stock-in trade and its sale after conversion, as per ITFG clarified as follows:
the IT Act. The tax treatment would be as follows: a. On the date of transition to Ind AS (1 April 2017),
• Capital gains tax: There would be capital gains a deductible temporary difference existed for Z
liability in respect of the conversion of capital asset Ltd. arising out of the carrying amount of asset
into stock-in-trade, at market value thereof on the (which is INR100 as on 1 January 2016) and its
date of conversion. Thus, the capital gains will be tax base (which is INR150 as on 1 January 2016,
computed as the difference between the indexed considering indexation benefit). Thus, on the
cost of capital asset to the assessee and the fair date of transition, the entity would recognise a
market value of such capital asset on the date of DTA for the deductible temporary difference of
its conversion into stock-in-trade. However, the tax INR50 in the value of land provided it satisfied
will be computed using the capital gains tax rate other DTA recognition criteria under Ind AS 12.
applicable in the year of actual sale and not in the b. The difference between the indexed cost of
year of conversion. Also, the capital gains tax will land on the date of conversion and its fair value,
be required to be paid only at the time of sale of the however, would not meet definition of temporary
stock-in-trade. difference under Ind AS 12. Additionally, the
• Profit/loss on sale of land as stock-in-trade: As business income under the IT Act would be
regard the sale of the stock-in-trade, any profit computed as a difference between the sale price
realised or loss incurred (i.e. difference between of the stock-in-trade (i.e. date of actual sale of
the sale proceeds and fair value on the date of inventory) and market value of the fixed asset
conversion) will be liable to tax as a business on the date of its conversion into stock-in- trade.
income. Such profit/loss would accrue and be liable Hence, such a tax liability would not arise on the
to tax at the time of sale of the stock-in-trade. If date of transition. (ITFG 17, Issue 7)
there is a business loss in the year of sale of stock- Deferred taxes on capitalised exchange differences
in-trade, the IT Act allows the loss to be offset
against capital gains arising on conversion. Thus, AS 11, The Effects of Changes in Foreign Exchange
the liability for capital gain tax on conversion is not Rates, provided a relief to the entities from reporting
sacrosanct and can vary depending on outcome adverse impact of volatility in exchange rate difference
from sale of stock-in-trade. by providing the following options:
Considering the above, conversion of capital asset into a. Adjust to the cost of the asset, where the long-
stock-in-trade would not require an entity to recognise term foreign currency monetary items relate
any current tax liability. Under the IT Act, the current to the acquisition of a depreciable capital asset
tax liability would arise only on the sale of stock-in- (whether purchased within or outside India),
trade. and consequently depreciate over such asset’s
balance life, or
An entity would need to consider deferred tax b. Accumulate in ‘Foreign Currency Monetary Item
implications under Ind AS 12 when a capital Translation Difference Account’ (FCMITDA) and
asset is converted into inventory. Additionally, amortise over the balance period of long-term
the recognition of DTA would be subject to monetary asset/liability but not beyond 31 March
consideration of prudence. 2020, in cases other than those falling under (a)
above.
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61
On transition to Ind AS, Ind AS 101 and Ind AS Ind AS 12 requires recognition of DTL on the
21, The Effects of Changes in Foreign Exchange undistributed reserves of subsidiaries except where
Rates, allow entities to recognise foreign exchange the parent is able to control the timing of reversal
adjustments as per the policy adopted under previous of the temporary difference and it is probable that
GAAP. Therefore, exchange differences arising from the temporary difference will not reverse in the
translation of long-term foreign currency monetary foreseeable future.
items recognised in the financial statements for the However, in case the board of directors of a subsidiary
period ending immediately before the beginning of the propose to declare dividend for the previous financial
first Ind AS financial reporting period can continue to year, to the extent of such proposed dividend, the
be accounted for as per the previous GAAP. temporary difference (in relation to DDT liability) is
Accordingly, certain entities that availed the relief considered to be probable to reverse.
provided by AS 11 would have added to or deducted In case where the parent is likely to claim the DDT
exchange gain/loss on foreign currency loan from paid by the subsidiary as an offset against its own
the cost of Property, Plant and Equipment (PPE), DDT liability, the ability to claim offset is subject to
before adoption of Ind AS. However, such exchange receipt of approval from the shareholders of the parent
differences capitalised are not allowed deduction (approval of dividend at the Annual General Meeting
under the IT Act including Income Computation and (AGM)).
Disclosure Standards (ICDS). In addition, entities
that chose to follow the previous GAAP accounting Accordingly, while it has been clarified that the parent
policy post transition, such adjustment would may be required to recognise DTL in the Consolidated
lead to temporary differences and recognition of Financial Statement (CFS) (measured based on the
deferred taxes through statement of profit and loss. DDT expense of the subsidiary) to the extent of
Such adjustments are likely to bring volatility to the proposed dividend of the subsidiary, recognition of
statement of profit and loss. DTA to the extent of offset may not be recognised
pending receipt of approval from the shareholders of
Entities would need to recognise deferred taxes the parent. (ITFG 9, Issue 1)
on such differences arising from the adjustment of
exchange difference to the cost of the asset. (ITFG 8, ITFG clarified in its clarifications’ bulletin 18, that
Issue 8) while dealing with the above issue, the intention was
not to preclude recognition of DDT credit in the CFS
Deferred taxes on undistributed profits in the period in which the parent receives dividend
The practical implications on accounting of deferred tax from a subsidiary. A parent should evaluate its facts
on undistributed profits are discussed in detail under and circumstances and if it reasonably expects at the
various situations as follows: reporting date that it would be able to avail of the DDT
i. When a parent receives dividend from its credit upon the declaration of dividend at its AGM (to
wholly-owned subsidiary during the year be held after the end of the financial year), it should
consider the following situations:
• Declaration of dividend by a parent is probable: At
the time of distribution of dividend by a subsidiary
to the parent (and consequent payment of DDT by
Dividend the subsidiary), the parent should recognise the
Wholly-owned Parent associated DDT credit as an asset to the extent that
subsidiary it is probable that a liability for DDT on distribution
of dividend by the parent would arise (against which
At the time of consolidation, the dividend income the DDT credit can be utilised).
earned by the parent would be eliminated against the • Declaration of dividend by a parent not probable: If it
dividend recorded in its equity by the subsidiary as is not probable that a liability for DDT on distribution
a result of consolidation adjustment. The Dividend of dividend by the parent would arise against which
Distribution Tax (DDT) paid by the subsidiary to the the DDT credit could be utilised, the amount of DDT
taxation authorities (being outside the consolidation paid by the subsidiary should be charged to profit or
group) would be charged as expense in the loss in the consolidated statement of profit and loss.
consolidated statement of profit and loss of the parent • Assessment of DDT credit at each reporting period:
(presuming that parent is unable to claim an offset At the end of each reporting period, the carrying
against its own DDT liability). amount of DDT credit should be reviewed. The
carrying amount of the DDT credit should be
reduced to the extent that it is no longer probable
that a liability for DDT on distribution of dividend by
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Ind AS Implementation Guide I 62
Dividend
Subsidiary Parent
Parent owns
60 per cent
stake in the
subsidiary
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63
It is important to note here, that the DDT paid to iii. DDT paid by an associate
the taxation authorities by the subsidiary has two Since DDT paid by an associate is not allowed to
components - that paid in relation to the parent entity be set-off against the DDT liability of the investor.
and the other paid in relation to Non-Controlling Therefore the investor’s share of DDT would be
Interest (NCI). As already explained earlier, the DDT accounted by the investor entity by crediting its
relating to the parent entity would be charged as tax investment account in the associate and recording a
expense in the consolidated statement of profit and corresponding debit adjustment towards its share of
loss of the parent since this is paid outside the group. profit or loss of the associate. (ITFG 13, Issue 9)
With regard to the DDT paid on dividend related to NCI,
it would be recognised in the statement of changes in Thus, entities which were recognising both, a deferred
equity along with the portion of such dividend paid to tax liability towards the subsidiary’s DDT liability and a
the NCI. deferred tax asset towards the offset to be claimed in
the future period may now be required to evaluate the
In the same situation, further, when the parent also impact of this clarification on their respective financial
pays dividend to its shareholders and assuming that statements. This may also create significant volatility
it is eligible to claim an off-set in respect of its DDT in the consolidated statements of profit and loss
liability to the taxation authorities to the tune of DDT especially in cases where the subsidiary declares a
paid by its subsidiary on its behalf. Then in such a large one-off dividend.
situation, the total amount of DDT (i.e. DDT paid by the
subsidiary as well as the additional DDT paid by the Additionally, for the purpose of interim financial
parent after utilising the offset claimed in respect of statements, necessary adjustment to the effective tax
DDT paid by the subsidiary) should be recognised in rates may be required to be considered.
the consolidated statement of changes in equity of the Applicability of Accounting Standards
parent entity since the share of the parent in the DDT Interpretation (ASIs) issued under previous GAAP
paid by the subsidiary was utilised by the parent for to situations of tax holiday under Ind AS
payment of dividend to its own shareholders. An entity may be entitled to tax holiday under Sections
In addition, it has been clarified that due to parent’s 80IA and 80IB of the IT Act.
transaction of distribution of dividend to its Under the previous GAAP, certain ASIs were issued by
shareholders (a transaction recorded in parent’s equity) the ICAI to provide guidance on applicability of
and the related DDT set-off, the DDT paid by the AS 22, Accounting for Taxes on Income, in the
subsidiary is effectively a tax on distribution of dividend situations of tax holiday under section 80IA and 80IB of
to the shareholders of the parent entity. Therefore, the IT Act. Some of these, subsequently were included
the DDT paid by the subsidiary and additional DDT in the relevant standard i.e. AS 22, by means of
paid by parent (on account of distribution of dividend explanations and thus became part of previous GAAP.
to its shareholders and claiming the off-set thereon)
should be recognised in the consolidated statement of
changes in equity of the parent entity and no amount Under Ind AS, the principles of Ind AS 12 would
would be charged to the consolidated statement of be applied to determine the treatment of
profit and loss. deferred taxes in the tax holiday period.
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Ind AS Implementation Guide I 64
AS 22 clarified that deferred taxes in respect of timing In this situation, it was assumed that the tax base of
differences which reverse during the tax holiday period the goodwill will be the amount that will be allowed as
should not be recognised to the extent the entity’s deduction in future in accordance with the IT Act.
gross total income is subject to the deduction during Additionally, this transaction will not qualify for the
the tax holiday period. However, timing differences initial recognition exemption under Ind AS 12 as
which reverse after the tax holiday period should be there is no initial recognition of an asset or liability
recognised in the year in which the timing differences arising from the amalgamation of subsidiaries in the
originate. CFS of parent entity (the impact of amalgamation of
ASIs are not effective in the context of Ind AS. Under subsidiaries is eliminated in the CFS of the parent
Ind AS, to determine the treatment of deferred taxes entity). (ITFG 10, Issue 3)
in the tax holiday period, the principles enunciated Treatment of income tax related interest and
in Ind AS 12 are required to be applied. Accordingly, penalties under Ind AS vis-a vis IFRS
under Ind AS, deferred taxes in respect of temporary
differences which reverse during the tax holiday period The Guidance Note on Division II - Ind AS Schedule III
should not be recognised in the financial statements to to the Companies Act, 2013 Act (GN) provides that any
the extent the entity’s gross total income is subject to interest on shortfall in payment of advance income tax
deduction during the tax holiday period in accordance is in the nature of finance cost and hence, should not
with the requirements of section 80IA/80IB of the IT be clubbed with the current tax. Rather, it should be
Act. (ITFG 11, Issue 2) classified as interest expense under ‘finance costs’.
Recognition of deferred tax on tax deductible
goodwill of subsidiary, not recognised in CFS Any interest on shortfall in payment of advance
income-tax is in the nature of finance cost. Hence,
Issue considered involved a situation where two
it should not be clubbed with the current tax, be
subsidiaries of an entity were amalgamated and as a
classified as interest expense under finance costs
result of this transaction, a goodwill was recognised
and disclosed separately.
in the SFS of the amalgamated entity under previous
GAAP. This goodwill was allowed as deduction under
income tax laws in the books of the amalgamated Similarly, any penalties levied under income tax laws
entity. On transition to Ind AS, the parent entity availed should not be classified as current tax. Penalties which
of the optional exemption under Ind AS 101 and are compensatory in nature should be treated as
decided not to restate its past business combinations. interest and disclosed under finance costs. Other tax
Accordingly, on the date of transition to Ind AS such penalties should be classified under ‘other expenses’.
accounting goodwill was eliminated as a result of
An entity’s obligation for current tax arises because
consolidation adjustment in the CFS. However, there
it earns taxable profit during a period. However, an
was an increase in the tax base of assets in the CFS
entity’s obligation for interest or penalties, arises
of parent entity resulting from such tax deductible
because of its failure to comply with one or more of
goodwill.
the requirements of income-tax law (e.g. failure to
In this situation an issue arises whether DTA on the tax deposit income-tax). Therefore, it was concluded that
deductible goodwill should be recognised in the CFS of the obligations for current tax and those for interest or
parent entity prepared as per Ind AS when there is no penalties arise due to reasons that are fundamentally
corresponding accounting goodwill in the CFS. different in nature. Ind AS 1, Presentation of Financial
A deferred tax may be recognised for assets or Statements, requires an entity to separately present
liabilities with a tax base but nil carrying amount in the items of a dissimilar nature or function unless they are
financial statements since Ind AS 12 states that some immaterial except when required by law. Therefore,
items may have a tax base but are not recognised as interest or penalties related to income tax cannot be
assets and liabilities in the balance sheet. clubbed with current tax.
Accordingly, DTA on the tax base of goodwill should be Additionally, it was highlighted that similarity in a
recognised in accordance with Ind AS 12 by crediting particular jurisdiction in the bases of computation of
the consolidated statement of profit and loss, to the amount of current tax and interest/penalties for non-
extent that it is probable that taxable profit will be compliance is not a sufficient ground for clubbing these
available against which the deductible temporary items, as they are different in terms of their nature.
difference can be utilised, in the CFS of the parent.
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65
The ITFG also considered the treatment of such a domestic company could give effect to lower tax
interest and penalties under IFRS. IFRS Interpretations rate (in accordance with the Ordinance 2019) while
Committee (IFRIC) in its meeting held on 12 determining current tax and DTA or DTL with the
September 2017 decided that entities do not have purpose to present interim results/interim financial
an accounting policy choice between applying IAS statements as on 30 September 2019 (financial year
12 and IAS 37, Provisions, Contingent Liabilities and 2019-20).
Contingent Assets to interest and penalties. Therefore, Even though, the lower rates of corporate income-
if an entity considers a particular amount payable or tax have been enacted (on 20 September 2019) well
receivable for interest and penalties to be an income before the interim reporting date of 30 September
tax, then the entity should apply IAS 12 to that amount. 2019, the ITFG has clarified that such lower rates
However, if an entity does not apply IAS 12 to a should be applied by a company for measurement
particular amount payable or receivable for interest and of current and deferred taxes only if it expects to opt
penalties, it should apply IAS 37 to that amount. Based for the lower rates. This is in accordance with the
on the IFRIC agenda, it was highlighted that an entity requirements of Ind AS 12.
should consider whether an amount of interest or a
penalty is in the scope of IAS 12 i.e. an entity should Accordingly, if the company expects to opt for the
consider whether the interest or penalty is a tax and lower tax rate (with an intention appropriately
whether that tax is based on taxable profits. evidenced), the current and deferred taxes are
required to be measured using lower tax rate as per
In cases, where it is difficult to identify whether an the Ordinance 2019 for the purpose of presenting
amount payable to (or receivable from) a tax authority interim results/interim financial statements for the
includes interest or penalties (for instance, single quarter/half year ended 30 September 2019.
demand issued by a tax authority for unpaid taxes),
entire amount would qualify within the meaning of IAS Additionally, it was clarified that in case the company
12. expects to opt for the lower tax rate from the next
financial year 2020-21 onwards, the lower tax rate is
An entity should determine whether a particular required to be applied only to the following extent:
amount payable or receivable for interest and
penalties is in the scope of IAS 12 (or Ind AS 12) after • The DTA is expected to be realised or
considering the tax laws applicable in its individual • The DTL is expected to be settled
jurisdiction i.e. an entity should consider whether in the periods during which the company expects to be
tax laws in the jurisdiction and other facts and subject to lower tax rate.
circumstances indicate that this amount is based on a
taxable profit (i.e. a ‘net’ amount). The normal tax rate is required to be applied to the
extent DTA/DTL is expected to be realised (settled) in
It was pointed out that interest and penalty payable earlier periods. (ITFG 23, Issue 1)
under Section 234A/B/C of the IT Act would not qualify
as income-taxes within the meaning of IAS 12 (or Accounting treatment of deferred tax adjustments
Ind AS 12). Therefore, the related amount would be recognised in equity on first-time adoption of
recognised as interest. Similarly, other interest and Ind AS in accordance with Ind AS 101, First-time
penalties under the IT Act would not generally qualify Adoption of Indian Accounting Standards at the
as income-taxes. (ITFG 16, Issue 2) time of transition to Ind AS 115 and Ind AS 116
Measurement of current tax and DTA/DTL to give An entity is required to determine (using the current
effect to concessional tax rates accounting polices) the underlying items (source
transaction/events) with respect to which deferred
The Taxation Laws (Amendment) Ordinance, 2019 taxes were recognised by it at the time of first-time
(Ordinance 2019) came into effect from 20 September adoption of Ind AS or at the time of transition to Ind AS
2019. It has brought out significant changes to 115 or Ind AS 116.
corporate income-tax rates. In accordance with the
Ordinance 2019, the domestic companies have now For more details on the issue please refer to the
been provided with an option to pay income-tax at Chapter 9, First-time adoption of Ind AS (ITFG 23,
a rate lower than the normal corporate income-tax Issue 2).
rate of 30 per cent depending upon certain specified
conditions. However, the option to pay income-tax at
a lower rate is dependent upon not availing certain
exemptions or incentives as specified in the Ordinance
2019. The issue under consideration was whether
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Ind AS Implementation Guide I 66
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67
6. Revenue
Summary
This chapter covers:
• Ind AS 115, Revenue from Contracts with Customers
Ind AS 115 lays down the principles to be followed for recognition, measurement, and
disclosures in respect of revenue from contract with customers.
Key principles
Overview of the five-step model
• Step 1: Identify the contract with customer – It has commercial substance i.e. the risk, timing
A contract is an agreement between two or or amount of the entity’s future cash flows is
more parties that creates enforceable rights and expected to change as a result of the contract.
obligations. It may be written, oral or implied by
customary business practices and meets all of the
following criteria:
– It is legally enforceable
– It is approved and all the parties are committed
to their obligations
– Rights to goods or services and payment terms
can be identified
– Collection of consideration is considered
probable
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Ind AS Implementation Guide I 68
• Step 2: Identify the performance obligations in stand-alone selling price of each distinct good or
the contract service (determined at contract inception). The
– At contract inception, entities are required to stand-alone selling price is determined as below:
identify as a performance obligation an implicit * Observable price: The best evidence of a
or an explicit promise to transfer to the customer stand-alone selling price is the observable
a distinct good or service (or bundle of goods or price of a good or service when the entity
services) sells that good or service separately in similar
– A good or service that is promised to a customer circumstances and to similar customers,
is distinct if both the following criteria are met: * Estimated price: If a stand-alone selling
* The good or service is capable of being price is not directly observable, an entity
distinct: Customers could benefit from the should estimate it by considering all
good or service on its own or with other information available to the entity, maximise
readily available resources. Various factors the use of observable inputs and apply
may provide such evidence, such as when estimation methods consistently in similar
the good or service can be used, consumed, circumstances. Some of the estimation
sold for an amount that is greater than methods are:
scrap value or held in a way that generates > Adjusted market assessment approach
economic benefits. > Expected cost plus a margin approach
The promise to transfer the good or service
*
Residual approach (only in limited
>
is distinct within the context of the contract: circumstances).
The promise to transfer the good or service is
• Step 5: Recognise revenue when (or as) the
separately identifiable from other promises in
entity satisfies a performance obligation
the contract.
• Step 3: Determine the transaction price – Revenue is required to be recognised when (i.e.
at a point in time) or as (i.e. over a period of time)
Determination of transaction price is done the entity satisfies a performance obligation by
by considering all amounts to which an entity transferring the control of a promised good or
expects to be entitled in exchange for transferring service to the customer.
promised goods or services excluding amounts
collected on behalf of third parties (for example, – A performance obligation is satisfied over time if
some sales taxes). Additionally, the consideration either:
may include fixed amounts, variable amounts, or * Customer simultaneously receives and
both. consumes the benefits as the entity performs
• Step 4: Allocating the transaction price to * Customer controls the asset as the entity
performance obligation creates or enhances it
– The objective of allocating transaction price * The entity’s performance does not create an
is for an entity to allocate transaction price to asset with an alternative use and there is right
each performance obligation in an amount that to payment for performance to date.
depicts expected entitlement for transferring the
– If a performance obligation is not satisfied
promised goods or services
over time, an entity satisfies the performance
– The stand-alone selling price is the price at obligation at a point in time.
which an entity would sell a promised good or
– Measurement of revenue is dependent upon the
service separately to a customer. Entities should
determination of the transaction price allocated
allocate the transaction price in proportion to the
to that performance obligation.
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69
Other principles
Significant differences from IFRS1
• Contract costs
– Incremental costs of obtaining a contract with a • IFRS 15, Revenue from Contracts with
customer are recognised as an asset, if they are Customers provides that all types of penalties
expected to be recovered which may be levied in the performance of a
contract should be considered in the nature of
Costs incurred to fulfil a contract are generally
–
variable consideration for recognising revenue.
recognised as an expense, however, in certain
Ind AS 115 excludes penalties from the list of
cases, they may be recognised as an asset.
variable consideration. Ind AS 115 has been
• Presentation amended to provide that penalties are required
– When either party to a contract has performed, to be accounted for as per the substance of
depending on the relationship between the the contract. Where the penalty is inherent in
entity’s performance and the customer’s determination of transaction price, it would
payment, a contract asset or a contract liability is form part of variable consideration, otherwise
presented in the balance sheet the same would not be considered for
Any unconditional rights to consideration are
–
determining the consideration.
separately presented as a receivable. • Ind AS 115 requires an entity to present
• Disclosures separately the amount of excise duty included
in the revenue recognised in the statement of
– The objective of the revenue disclosures is to
profit and loss. There is no such requirement in
enable users to understand the nature, amount,
IFRS 15.
timing and uncertainty of revenue and cash flows
arising from contracts with customers. • Additional disclosures as compared to IFRS
15 are prescribed. An entity is required to
At a Over-time
point if specific
in time criteria are
when the met
customer
obtains
control
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Ind AS Implementation Guide I 70
If none of the above criteria are met, then control of Further, ITFG clarified that basis the above evaluation
the good or service transfers at a point in time. of criteria, if entity concludes that the performance
In the above context, ITFG considered an issue obligation of the entity under its contract with a
relating to a shipping entity involved in transportation customer is satisfied over time, then the entity is
of petroleum products from one port to other. required to determine an appropriate method of
measuring progress on the basis of the relevant
The contracts with customers state that the contract
requirements and guidance contained in Ind AS 115.
would not be terminated once the entity takes delivery
(ITFG 19, Issue 2)
of goods from the customers at the port and sails
to the designated port of destination. The following First-time adopter of Ind AS transitional
issues in respect of performance obligations under the options under Ind AS 115
contract were considered by the ITFG:
For existing Ind AS users Ind AS 115 provides
i. Whether the performance obligation under the two methods of accounting for transition - the
above contract is satisfied over time or at a point in retrospective method (with or without one or more of
time four practical expedients) and the cumulative effect
ii. In case the performance obligation under the above method (simplified transition method).
contract is satisfied over time, whether the extent In a situation where an entity (ABC Ltd.) complying
of satisfaction of performance obligation could be with Ind AS for the first time from 1 April 2018 is
measured on the basis of number of days the vessel required to comply with Ind AS 115, ITFG clarified
has sailed. that a first-time adopter does not have the choice of
Whether the performance obligation is satisfied applying the simplified transition method.
over time or at a point in time Please refer to the Chapter 9, First-time adoption of
ITFG clarified that in the given case, the entity Indian Accounting Standards for more details on the
would need to evaluate its performance obligation to above issue (ITFG 19, Issue 3)
determine if it satisfies any of the requisite criterion.
Accounting treatment of deferred tax
For evaluating criteria (a), in the given case an
adjustments recognised in equity on first-
entity may not be able to readily identify whether a
customer simultaneously receives and consumes the time adoption of Ind AS in accordance
benefits from its performance. The entity is required with Ind AS 101, First-time adoption of
to evaluate whether another entity would need to Indian Accounting Standards at the time
substantially re-perform the work carried out by the of transition to Ind AS 115/116, Leases
entity to date. If that work would not need to be Please refer to the chapter 9, First-time adoption of
substantially re-performed, then revenue would be Ind AS for more details on the above issue (ITFG 23,
recognised over time. Issue 2)
Considering the nature of performance obligation of
the entity, it would not be meeting criterion (b) as Applicability of Ind AS 115 to distribution
it would not be able to create or enhance an asset of gifts
that the customer controls as the asset is created or Revenue is accounted for in accordance with Ind AS
enhanced. 115, only in case the counterparty to the contract
In the given case, for evaluation of criterion (c), an is a customer. Further, a contract should create
entity should consider whether the performance enforceable rights and obligations.
obligation creates an alternative use to it. Additionally, In case the conditions regarding a legally enforceable
in determining whether it has an enforceable right to ‘contract’ and ‘customer’ are not met, the transaction
payment for performance completed to date requires would not fall within the scope of Ind AS 115.
consideration of the detailed requirements and Please refer to the chapter 4, Tangible and intangible
guidance provided in Ind AS 115. assets for more details on the above issue (ITFG 22,
Measurement of progress towards complete Issue 4)
satisfaction of a performance obligation
Expected Credit Loss (ECL) on the amount
Ind AS 115 specifies the following two types of
methods for measuring progress based on the nature
due in the course of business from
of the goods or services that the entity promised to government
transfer to the customer: Please refer to the chapter 3, Financial instruments
• Input method for more details on the above issue (EAC opinion
published in the October 2018 edition of the Journal
• Output method. ‘The Chartered Accountant)
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71
21 Determining the transaction price in case of collection of Goods and Services Tax (GST)
22 Determining the transaction price for financial statements vis-à-vis sales for GST purpose
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Ind AS Implementation Guide I 72
26 Determining the transaction price when fees received to provide a loan commitment
27 Allocating the transaction price to performance obligations
28 Allocating the transaction price to sales incentives (cash and non-cash)
29 Allocating the transaction price to performance obligations in case of a discount
30 Allocating the transaction price to performance obligations and treatment of incentive
31 Accounting treatment of reward points
32 Allocating the transaction price in situations of separately identifiable performance obligations
33 Transfer of control in situations of raising an invoice or transfer of legal title
Recognising revenue when performance obligation is satisfied (dispatch and installation of
34
goods)
35 Recognising revenue when performance obligation is satisfied over time
Recognising revenue in situations of non-refundable upfront fees and sales based monthly
36
royalty income
Recognising revenue in situation of collection based on achievement of sales target by
37
customer
Recognising revenue as and when entity satisfies each performance obligation (unused
38
contracted call minutes in relation to telecommunication entity)
Recognising revenue as and when entity satisfies each performance obligation (broadband data
39
services)
Recognising revenue as and when entity satisfies each performance obligation (sale contract
40
based on prices linked to organised market)
Recognising revenue when entity satisfies each performance obligation (measurement of the
41
outcome of the performance obligation)
42 Recognising revenue in situations of one-time upfront charges
Recognising revenue in situations of transfer of control of goods (when a transporter is involved
43
and delivery terms are Cost, Insurance and Freight (CIF))
44 Recognising revenue in contract of payroll processing for a year with monthly payment
Recognising revenue by use of input method based on costs incurred to measure progress of
45
performance obligation
46 Guidance on whether a ‘contract asset’ is a ‘financial instrument’
2. This issue has been analysed in light of Ind AS 115 and erstwhile Ind AS 17, Leases. Ind AS 17 has been superseded by Ind AS 116, Leases with effect
from 1 April 2019. Accordingly, users should revisit this issue in light of guidance provided under Ind AS 116.
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73
Issue
Topic
number
52 Guidance for an Asset Management Company (AMC) in situation of variable consideration
53 Guidance in situations where manufacturer enters into a consignment agreement with a retailer
Information of contract to be included in disclosure of the transaction price allocated to the
54
remaining performance obligations as per requirements of Ind AS 115
Guidance on whether disaggregated revenue disclosure always would be at the same level as
55
its segment disclosures
56 Guidance on presentation of advance from customer
Guidance on treatment of cost of obtaining contracts in situations of discretionary annual bonus
57
to employees and other costs
Guidance on differential sales commission to employees based on their designations to be
58
treated as costs of obtaining contracts
59 Guidance on training expenses to be treated as cost of fulfilling contracts
60 Guidance on transition requirements under modified retrospective approach
Measurement of transaction price in case of revenue recognised over a period by a real estate
74
developer
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Ind AS Implementation Guide I 74
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75
7. Leases
Summary
This chapter covers:
• Ind AS 116, Leases
Key principles
• Ind AS 116 applies to leases of Property, Plant and – Lessors apply a dual model and classify leases as
Equipment (PPE) and other assets, with only limited either finance or operating leases.
exclusions. Lessee accounting
• A contract is, or contains, a lease if the contract • Ind AS 116 requires the following accounting
conveys the right to control the use of an identified treatment in the books of the lessee, on the
asset for a period of time in exchange for commencement of the lease:
consideration.
– A lessee recognises a Right-Of-Use (ROU) asset
Accounting model representing its right to use the underlying asset
• There are different accounting models for lessees and a lease liability representing its obligation to
and lessors as described below: make lease payments.
– Lessees apply a single on-balance sheet – A lessee measures the ROU asset at cost less
lease accounting model, unless they use the accumulated depreciation and accumulated
recognition exemptions for short-term leases impairment losses.
and leases of low-value assets.
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Ind AS Implementation Guide I 76
Lessor accounting
Significant differences from IFRS1
• A lessor is required to classify each of its leases
(as either an operating or a finance lease) at the
• With regard to the subsequent measurement
inception date and is reassessed only if there is a
of leases in the books of the lessee, IFRS 16,
lease modification. The classification depends on
Leases, provides that if lessee applies fair value
whether substantially all of the risks and rewards
model in IAS 40, Investment Property, to its
incidental to ownership of the leased asset have
investment property, then it should apply that
been transferred from the lessor to the lessee.
fair value model to the ROU assets that meet
• Under a finance lease, a lessor derecognises the definition of investment property. Since Ind
the leased asset and recognises a finance lease AS 40, Investment Property, does not allow the
receivable. use of fair value model, this guidance has not
• Under an operating lease, the lessor treats the lease been included in Ind AS 116.
as an executory contract and recognises the lease • IFRS 16 requires classification of cash
payments as income over the lease term. The lessor payments for interest portion of lease liability
recognises the leased asset in its balance sheet. applying requirements of IAS 7, Statement of
Cash Flows. IAS 7 provides option of treating
Sale-and-leaseback transactions
interest paid as operating or financing activity.
• In a sale-and-leaseback transaction, the seller-lessee However, Ind AS 7, Statement of Cash Flows
first determines if the buyer-lessor obtains control of requires interest paid to be treated as financing
the asset based (i.e. whether transfer of asset is a activity only. Accordingly, the related guidance
sale of that asset). has been modified in Ind AS 116 to specify
• If the transaction does not qualify for sale that cash payments for interest portion of
accounting (i.e. transfer of asset is not a sale), then lease liability would be classified as financing
it is accounted for as a financing transaction. activities applying Ind AS 7.
Sub-lease transactions
• In a sub-lease transaction, the intermediate lessor
accounts for the head lease and the sub-lease as
two separate contracts.
• An intermediate lessor classifies a sub-lease with
reference to the ROU asset arising from the head
lease.
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77
Guidance from ITFG clarifications rights and obligations existing between the lessee
and the lessor beyond that term then there is no
contract beyond the non-cancellable period. (ITFG
Ind AS 116 requires a lessee to recognise a ROU asset 21, Issue 1 and ITFG 22, Issue 1)
in its books subject to certain exemptions provided in
the lease standard. These exemptions include short-
term leases. For the purpose of accounting for a lease In determining whether the lease is a short-term,
in the books of a lessee, the determination of the the enforceable rights of the lessee only are
lease term is an important consideration and would considered.
be based on facts and circumstances of the lease
agreement.
Determination of the lease term
Lease agreement does not provide purchase
The ITFG has clarified that in determining the lease option to the lessee
term (and consequently whether a lease is a short-
term lease), only the enforceable rights of the lessee In a situation, PQR Ltd. (the lessee) leased an office
to renew or extend the lease beyond the non- building from ABC Ltd. (the lessor) by means of an
cancellable period are taken into consideration. For agreement for a period of one year in the year 2005.
example, Other facts of the case are as follows:
• In case a lease agreement grants a lessee a right • The contract has been renewed every year for a
to renew or extend the lease beyond the non- further period of one year at each renewal date.
cancellable period without the consent of the lessor: • In accordance with past practice, it is likely that
In such a case, the period covered by the lessee’s the contract would be renewed for another one
option to renew or extend the lease is included in year at the expiry of its current term. However, the
the lease term if the lessee is reasonably certain to lease agreement does not provide PQR Ltd. with a
exercise that option. purchase option in respect of the leased asset (i.e.
• In case a lease agreement, in which the lessee the office building).
can renew or extend the lease beyond the non- The issue under consideration was whether PQR Ltd.
cancellable period only with the consent of the could avail the recognition exemption for short-term
lessor: In such a case if there are no enforceable leases in accordance with Ind AS 116.
Lease renewed for one year at each renewal date since 2005
Mutual consent of both lessor and lessee required for renewal upon expiry
Accordingly, ITFG clarified that a lease agreement A lease with above characteristics would be
qualifies as a short-term lease in accordance with Ind considered as a short-term lease even if there is a
AS 116, in case it (i.e. the lease agreement including past practice of the lease being renewed upon expiry
any addendum thereto or a side agreement) has all of of the lease term (with the mutual consent of both the
the following characteristics: lessor and the lessee).
• It is for a period of 12 months or less Hence, in the given scenario, ITFG clarified that as the
lease agreement qualifies as a short-term lease, PQR
• It does not grant a renewal or extension option to
Ltd. could avail the recognition exemption for short-
the lessee
term leases as given in Ind AS 116. (ITFG 21, Issue 1)
• It does not grant a purchase option to the lessee.
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Ind AS Implementation Guide I 78
Lease agreement with different options • X has no tenancy or right or interest in the land
In another case, an entity X is in the business of • As per the past practice followed by Y in respect of
power generation and transmission and has a licence its other similar leases, it is likely that the contract
for 30 years. Following are three scenarios related to would be renewed for another ten years at the
various lease agreements entered into by it: expiry of its current term
Scenario 1: Lease could be terminated by giving • X is reasonably certain to continue the above lease
one month’s prior notice till the validity of transmission licence, i.e. 30 years
During the year 2015, X (lessee) entered into a lease since shifting of transmission lines would affect its
arrangement with another entity Y (lessor) (which is a business adversely
government-owned railway operator) for an overhead
• In the past, Y has given notice to lessees to shift
line facility across the railway track for a period of 10
transmission lines from railway land only in a few
years. Other facts of the case are as follows:
rare and unusual cases.
• X paid ‘way leave’ charge to Y for the right of way in
advance for the entire period of 10 years
Lessee X Lessor Y
The ITFG clarified that in determining the lease term, decision) are likely to be significantly less than the
the lessee (i.e. X in this case) is required to make cost involved in relocation.
an assessment if, at lease commencement, there is
• In case the premature termination by X would result
an economic incentive to not exercise the option to
in Y forfeiting a significant part of the advance lease
terminate the lease prematurely.
rental payment, this would be an additional factor
X would make this assessment by considering all providing economic incentive to X to not terminate
relevant facts and circumstances including any the lease prematurely.
expected changes in facts and circumstances during
Further, in the given situation, Y is a government-
the 10 years period.
owned entity. While its agreement with X gives it
In the current scenario, however, the following factors a right to terminate the lease at any time, it seems
prima facie suggest that at the commencement that this right is meant to be exercised only in
date, X is not likely to have an economic incentive to exceptional circumstances. At lease commencement,
exercise the termination option: there seems to be no economic incentive for Y to
• X expects to operate the transmission line for 30 terminate the lease prematurely. In case another
years and therefore, needs the right of way for a entity approaches Y for the right of way, it seems that
period of 30 years. it can provide the right of way at some distance from
location of transmission line of X. Y does not need to
• In case X wishes to relocate the transmission line
terminate its existing arrangement with X to provide
so that it crosses over the railway track at a different
right of way to another party.
location, in all likelihood, it would still have to obtain
the right of way from Y. The above factors, all, prima facie suggest that at
lease commencement, it is reasonably certain that the
• It seems possible that X may not be able to
termination option would not be exercised. However,
have a complete transmission line without
as mentioned earlier, the final determination of the
crossing over the railway track. Even where this
issue would have to be made by X on the basis of
is technically possible, the alternative route may
its detailed and in-depth knowledge of the facts and
involve a considerable increase in the length of
circumstances of the case. In case X concludes that it
the transmission line and may therefore involve
is reasonably certain at lease commencement that the
considerable additional cost. Prima facie, any
termination option would not be exercised, the lease
savings to X due to lower lease rentals (which are
term would be 10 years and, consequently, the lease
likely to be the primary drivers behind any relocation
would not qualify as a ‘short term lease’.
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79
Scenario 22: Agreement for 12 months but no • X should not transfer or sublet the rights granted by
renewal or extension or purchase option to the Z and the benefit of the facility should be restricted
lessee only (i.e. mutual consent required) to it only.
A part of the transmission line also passes through • Since the year 2015, the contract has been renewed
private land held by Z. During the year 2015, X (lessee) every year for a further period of one year at a time.
entered into a lease agreement with Z (lessor) for a X is reasonably certain to continue the above lease till
period of 12 months for overhead facility. the validity of transmission licence, i.e. 30 years since
The following are some of the principal terms of shifting of transmission lines would affect its business
agreement: adversely.
• The lease can be renewed or cancelled with the As per the past practice, it is likely that the contract
mutual consent of both the parties. will be renewed for another one year at the expiry of
• Either party is at liberty to put an end to the its current term.
arrangement by giving one month’s prior period The lease agreement does not provide any purchase
notice in writing. In the event of such a notice option in respect of the leased asset to the lessee.
neither party should have any claim for any
compensation.
In the given situation, the ITFG clarified that the lease one year. Other facts are as follows:
agreement is for a period of 12 months and qualifies • The lease can be renewed for a further period of one
as a short-term lease. This is because the agreement year with the mutual consent of both the parties
does not grant a renewal or extension or purchase
option to X (i.e. the renewal of lease requires mutual • There is no penalty if the lessee and the lessor
consent of both parties and is not at the option of X do not agree. Since 2016, the contract has been
only). renewed every year for a further period of one year
at a time
Scenario 32: Agreement for 12 months but no
renewal, extension or purchase option to the • As per the past practice, it is likely that the contract
lessee only (i.e. mutual consent required) will be renewed for another one year at the expiry of
its current term.
In the year 2016, X enters into a lease agreement with
a warehouse for an initial non-cancellable period of
Lessee X
Lessor is a warehouse
The ITFG has clarified that in this scenario as well, the lease agreement is for a period of one year i.e.12
months. (ITFG 22, Issue 1)
2. A similar issue related to renewal of lease requiring mutual consent of lessor and lessee and not just at the option of lessee has been clarified in ITFG
clarification bulletin 21 (Issue 1).
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Ind AS Implementation Guide I 80
Accounting treatment of rent equalisation liability of the following two options would be applied:
ABC Ltd. (the lessee), had several long-term lease Option I: ROU asset is measured as if Ind AS 116
contracts for lease of office buildings, cars, etc. and had been applied since the commencement date,
had classified them as operating leases under Ind AS but discounted using the lessee’s incremental
17, Leases. Under Ind AS 17, the related lease rentals borrowing rate at the date of initial application. The
were recognised on a straight-line basis over the lease accounting would be as follows:
term of the respective leases taking into consideration – The difference as at the date of initial application
the 10 per cent escalation in lease rentals every year. between the ROU asset (together with lease
Therefore, ABC Ltd. recognised a rent equalisation equalisation liability) and lease liability would
liability in its balance sheet as on 31 March 2019. be recognised in retained earnings (or other
Ind AS 116 provides two optional approaches to a component of equity, as appropriate)
lessee for transition as follows:
– Comparatives would not be restated
• Full retrospective approach (no practical expedient)
– A third balance sheet would not be presented at
• Modified retrospective approach (with practical the beginning of the preceding period (i.e. 1 April
expedient). 2018).
The accounting treatment of rent equalisation liability Option II: ROU asset is measured at an amount
appearing in the balance sheet of ABC Ltd. when it equal to the lease liability: The accounting would be
applies Ind AS 116 is explained as below: as follows:
• Application of full retrospective approach – Consider rent equalisation liability as accrued
Under this approach, the lessee applies Ind AS lease payments and the amount of ROU would
116 retrospectively in accordance with Ind AS be determined by deducting the said liability
8, Accounting Policies, Changes in Accounting from the amount of lease liability
Estimates and Errors. – Comparatives would not be restated
The accounting treatment of transition from Ind AS – A third balance sheet would not be presented at
17 to Ind AS 116 would be as follows: the beginning of the preceding period (i.e. 1 April
– For each lease, the amount of the lease liability 2018). (ITFG 21, Issue 2)
and the related ROU asset as at the beginning Non-refundable lease premium amount equal to
of the preceding period (i.e.1 April 2018) would market value
be determined as if Ind AS 116 had always been XYZ Ltd. (a manufacturing entity and a lessee)
applied. acquired a plot of land several years back on a 99
– The difference between the ROU asset (together years lease from Industrial Development Corporation
with lease equalisation liability) and lease liability (ID Corp) (the lessor) of the State Government for its
would be recognised in retained earnings (or business purposes. An upfront non-refundable lease
other component of equity, as appropriate). premium was paid at the time of execution of lease
– The comparative amounts presented in the deed (equal to market value of the land at that time).
financial statements for the year ended 31 March Additionally, the lessee would pay a nominal lease rent
2020 would be restated. on an annual basis over the entire 99 years period (i.e.
the lease term).
Additionally, in accordance with the requirements
of Ind AS 1, Presentation of Financial Statements, However, XYZ Ltd. could transfer the leased land to a
if the retrospective application of Ind AS 116 has third party after prior consent of the ID Corp.
a material effect on the information in the balance The lease deed does not have any specific clause on
sheet at the beginning of the preceding period (i.e., renewability upon completion of abovesaid lease term
1 April 2018), a third balance sheet as at 1 April of 99 years. Also, the website of the ID Corp mentions
2018 would also need to be presented. lease would be renewable after the expiry of 99 years
• Application of modified retrospective approach but not clear if any further lease premium would need
to be paid upon completion of 99 years of lease to
Under the modified retrospective approach, either renew the lease.
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81
In this situation, ITFG considered the following issues: Accounting for foreign exchange differences
a. Upfront payment equal to the present value of relating to lease liability
payments over the lease term In accordance with Ind AS 101 a first-time adopter is
ITFG deliberated on whether the transaction permitted to continue with its previous GAAP policy
described is a lease within the meaning of Ind AS adopted for accounting for exchange differences
116 specifically when the upfront payment made arising from translation of Long-Term Foreign Currency
by the lessee accounts to almost all of the present Monetary Items (LTFCMI) recognised in its financial
value of the payments to be made over the lease statements for the period ending immediately before
term. the beginning of the first Ind AS financial reporting
period. (Paragraph D13AA of Appendix D to Ind AS
Considering the definition under Ind AS 116, it was
101)
clarified that for a contract (or a part of a contract) to
qualify as a lease, exchange of consideration for the In a situation an entity, (applying the requirements
ROU of the underlying asset is essential. However, of Ind AS 116), recognised a lease liability and a
the timing or pattern of flow of such consideration ROU asset as at 1 April 2019 in respect of a long-
is not relevant in determining whether or not an term lease. This lease was entered into before the
arrangement is a lease. beginning of its first Ind AS financial reporting period
and was classified as an operating lease under the
In the present situation, the lease deed executed
previous GAAP (i.e. under AS 17). The lease payments
between the entity and the ID Corp creates
are denominated in a foreign currency.
enforceable rights and obligations between the
two parties and thus, constitutes a contract. This The issue under consideration was with regard to
contract conveys the ROU of a specified parcel of accounting of foreign exchange differences relating
land (the underlying asset) to the entity for 99 years to lease liability recognised by the entity. The ITFG
in exchange for upfront payment of lease premium deliberated if such foreign exchange differences
and annual payment of lease rent (consideration). would be covered by the exemption provided under
paragraph D13AA of Ind AS 101 or these should be
Accordingly, in the current situation, the ITFG
recognised in the statement of profit and loss.
clarified that the lease deed qualifies as a lease
within the meaning of Ind AS 116, even though The ITFG clarified that the exemption provided by
almost all of the consideration has been paid paragraph D13AA of Ind AS 101 is available only
upfront. in respect of LTFCMI recognised in the financial
statements for the period ending immediately before
b. Accounting treatment of the lease in the books
the beginning of the first Ind AS financial reporting
of the lessee
period as per the previous GAAP.
The accounting treatment of the lease in the books
Additionally, Ind AS 101 specifically provides that an
of lessee in accordance with Ind AS 116, when it
entity should not apply the exemptions contained in
was classified as a finance lease under Ind AS 17
Appendices C-D by analogy to other items.
would be as follows:
Accordingly, ITFG clarified that foreign exchange
• Lease liability: The amount of lease liability
differences relating to the lease liability recognised by
immediately upon transition to Ind AS 116 would
the entity should be charged to the statement of profit
be similar regardless of whether the entity
and loss (ITFG 21, Issue 5).
applies full retrospective approach or modified
retrospective to account for the transition.
• ROU asset: The amount of ROU asset In situations where lease liability is denominated
immediately upon transition to Ind AS 116 would in foreign currency and would be considered as
be similar regardless of whether the entity a monetary item. This liability would need to be
applies full retrospective approach or modified translated at the closing exchange rate at each
retrospective to account for the transition. reporting date as per Ind AS 21, The Effects of
• Lease term: If the lease term was correctly Changes in Foreign Exchange Rates. However,
determined by the lessee under Ind AS 17, the the ROU asset would not be restated. This would
same assessment of lease term would continue potentially create volatility in the statement of
under Ind AS 116. Further, a leasehold land is a profit and loss.
depreciable asset even if the lease term is very
long unless the title transfers to the lessee at
the end of the lease term or the lessee has a
purchase option that is reasonably certain to be
exercised. (ITFG 21, Issue 3)
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Ind AS Implementation Guide I 82
Lessor accounting for lease rental income in case in accordance with Ind AS 116 as follows:
of on operating lease • Y Ltd. is required to recognise operating lease
In respect of accounting for operating leases by a rentals from the office building given on lease on a
lessor, Ind AS 17 did not require or permit scheduled straight-line basis over the lease term, even though
lease rental increases to be recognised on a straight- the lease rentals are structured to increase in line
line basis over the lease term if lease rentals were with expected general inflation to compensate for
structured to increase in line with expected general its expected inflationary cost increases.
inflation to compensate for the lessor’s expected
• The resultant change in manner of recognition
inflationary cost increases. Instead, Ind AS 17 required
of operating lease rentals by Y Ltd. represents a
such increases to be recognised in the respective
change in an accounting policy which would need to
period of increase. This was a significant difference
be accounted for as per Ind AS 8 in the absence of
(a carve-out) from its corresponding international
specific transitional provisions in Ind AS 116 dealing
standard IAS 17, Leases.
with the change. (ITFG 22, Issue 2)
However, it is important to note there is no such
Accounting of operating leases of a subsidiary not
carve-out in Ind AS 116. Thus, Ind AS 116 requires
capitalised by a first-time adopter parent
operating lease rentals to be recognised on a straight-
line basis (or on another systematic basis if such Please refer to the Chapter 9, First-time adoption of
other basis is more representative of the pattern in Ind AS for more details on the above issue (ITFG 21,
which benefit from the use of the underlying asset is Issue 4)
diminished). Accounting for mining lease rights in accordance
An entity Y Ltd. (lessor) entered into a lease with Ind AS
agreement to provide on lease an office building to The accounting for mining for extraction of lime stone
another entity X Ltd. (lessee) for a period of five years or similar such resources is excluded from the scope
beginning 1 April 2017. of Ind AS 116.
• The lease rental for each subsequent year was to Please refer to the Chapter 4, Tangible and intangible
increase by 10 per cent over the lease rental for the assets for more details on the above issue. (ITFG 22,
immediately preceding year Issue 3)
• The scheduled 10 per cent annual increase in lease Accounting treatment of deferred tax adjustments
rentals was in line with expected general inflation to recognised in equity on first-time adoption of Ind
compensate for Y Ltd.’s expected inflationary cost AS in accordance with Ind AS 101, at the time of
increases. transition to Ind AS 115/Ind AS 116
Y Ltd. did not recognise the lease rental income on a Please refer to the Chapter 9, First-time adoption of
straight-line basis. Ind AS for more details on the above issue. (ITFG 23,
Issue 2)
The ITFG considered and clarified the accounting of
the rental income of the operating lease by the lessor,
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83
8 Guidance on criterion of an identified asset (the capacity portion used in a warehouse facility)
Guidance on criterion of an identified asset (the capacity portion used in the pipeline) in
9
situations of ‘right of first refusal’
10 Guidance on arrangement containing a lease (explicit or implicit identification of an asset)
Guidance on an arrangement containing a lease under Ind AS 116 vis a vis Appendix C of Ind AS
22
17
Assessment of whether an arrangement is a lease where no enforceable rights and obligations
23
of parties nor exchange of consideration exists
26 Assessment of lease term for assessing ROU asset and lease liability in different scenarios
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Ind AS Implementation Guide I 84
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85
Issue
Topic
number
Guidance on subsequent measurement of ROU asset when the underlying asset belongs to a
55
class of asset for which an entity has elected the revaluation model under Ind AS 16
56 Guidance on impairment of ROU asset
57 Guidance on lease payments in foreign currency
58 Guidance on variable lease payments dependent on an index
Guidance on whether the interest on lease liability and depreciation on ROU asset could be
59
included in PPE or inventories
60 Guidance on reassessment in lease liability due to change in lease term
61 Guidance on when lease modification is not considered as a separate lease
62 Guidance on lease modification when considered as a separate lease
Guidance on lease modification in case where reduction in lease term leading to a change in
63
terms of the lease
64 Guidance on lease modification in a situation of change in consideration
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Ind AS Implementation Guide I 86
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87
8. Effects of changes
in foreign exchange
rates
Summary
This chapter covers:
• Ind AS 21, The Effects of Changes in Foreign Exchange Rates
Key principles
General principles Functional currency
Ind AS 21 should be applied in: • The entity measures its assets, liabilities, income
• Accounting for transactions and balances in foreign and expenses in its functional currency, which is
currencies, except for those derivative transactions the currency of the primary economic environment
and balances that are within the scope of Ind AS in which it operates. An entity’s functional currency
109, Financial Instruments reflects the underlying transactions, events and
conditions that are relevant to it. Accordingly, once
• Translating the results and balance sheet of determined, the functional currency is not changed
foreign operations that are included in the financial unless there is a change in those underlying
statements of the entity by consolidation or the transactions, events and conditions.
equity method and
• Transactions that are not denominated in an
• Translating an entity’s results and balance sheet into entity’s functional currency are foreign currency
a presentation currency. transactions.
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Ind AS Implementation Guide I 88
Recognition
Initial recognition
• A foreign currency transaction should be recorded
in the functional currency, by applying to the foreign
currency amount the spot exchange rate between
the functional currency and the foreign currency at
the date of the transaction.
Subsequent measurement
• At the end of each reporting period:
– Foreign currency monetary items should be
translated using the closing rate
– Non-monetary items that are measured in terms
of historical cost in a foreign currency should be
translated using the exchange rate at the date of
the transaction and
– Non-monetary items that are measured at fair
value in a foreign currency should be translated
using the exchange rates at the date when the
fair value was measured.
Presentation currency Significant differences from IFRS1
• The entity may present its financial statements
in a currency other than its functional currency • Ind AS 101, read with Ind AS 21, provides
(presentation currency). The entity that translates companies with an option to continue the
its financial statements into a presentation currency policy adopted as per previous GAAP/AS in
other than its functional currency uses the same accounting for exchange differences arising
method as for translating the financial statements of from translation of long-term foreign currency
a foreign operation. monetary items recognised in the financial
statements for the period ending immediately
Disposal or partial disposal of a foreign before the beginning of the first Ind AS financial
operation reporting period.
• If an entity disposes of its entire interest in a foreign • When there is a change in functional currency
operation or loses control over a foreign subsidiary, of either the reporting entity or a significant
or retains neither joint control nor significant foreign operation, IAS 21, The Effects of
influence over an associate or joint arrangement Changes in Foreign Exchange Rates, requires
as a result of partial disposal, then the cumulative disclosure of that fact and the reason for the
amount of the exchange differences relating change in functional currency. Ind AS 21 requires
to that foreign operation, recognised in Other an additional disclosure of the date of change in
Comprehensive Income (OCI) and accumulated functional currency.
in the separate component of equity, should be
reclassified from equity to the statement of profit
and loss (as a reclassification adjustment) when the
gain or loss on disposal is recognised.
• A partial disposal of a foreign subsidiary without the
loss of control leads to proportionate reclassification
of the cumulative exchange differences from OCI to
Non-Controlling Interest (NCI).
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89
Practical implications arising out of ITFG Additionally, the auditor of such an entity (whose
clarifications financial statements are prepared in a presentation
currency which is different from its functional
Determination of functional currency currency) would be required to give an auditor’s report
Often situations arise where a company may have on financial statements prepared in the presentation
two or more distinct business with different functional currency. (ITFG 7, Issue 2)
currencies. The accounting principles in Ind AS 21 Disclosure of foreign exchange differences
provide that functional currency is the currency of the separately from other fair value changes
primary economic environment in which the entity
Generally, Ind AS 109 requires a gain or loss on
operates.
a financial asset that is measured at fair value to
be recognised in profit or loss2. In the case of a
Functional currency needs to be identified financial asset denominated in a foreign currency and
at the entity level, considering the economic measured at Fair Value Through Profit or Loss (FVTPL),
environment in which the entity operates, and not the fair value is determined in the following two steps:
at the level of a business or a division. a. Firstly, the fair value is determined in the relevant
foreign currency
Ind AS 21 provides additional guidance with respect b. Next, it is translated into the functional currency in
to factors which an entity should consider while accordance with the requirements of Ind AS 21.
determining its functional currency. These factors Thus, as explained above, the change in fair value of
include the following: such a financial asset during a period arises due to
a. Currency that influences sales prices for goods following two factors:
and services and is of a country whose competitive a. Change in fair value expressed in terms of foreign
forces and regulations determine the sales prices of currency
its goods and services b. Change in exchange rate.
b. Currency that influences labour, material and other In a scenario discussed at ITFG, an entity, P Ltd. holds
costs of providing goods or services an investment in debentures3 denominated in a foreign
c. Currency in which funds from financing activities currency. These debentures are measured at FVTPL
are generated and in accordance with Ind AS 109, and the functional
d. Currency in which receipts from operating activities currency of P Ltd. is INR.
are usually retained. (ITFG 3, Issue 3)
Determination of presentation currency for CFS
Entities within a group may have different functional
currencies. Ind AS 21 requires each entity to determine
its functional currency and translate foreign currency
items into functional currency and report effects of
such translation in the financial statements. Ind AS 21 P Ltd Foreign currency
also permits an entity to use a presentation currency (Functional debentures
for reporting its financial statements that differs from currency: INR) (measured at
its functional currency. FVTPL)
Ind AS 21 provides specific guidance on translating the
results and balance sheet of an entity into a different 2. The exceptions to this general principle are as follows:
presentation currency. a. It is a part of hedging relationship
b. It is an investment in an equity instrument and the entity has elected
to present gains and losses on that investment in OCI
If an entity is statutorily required to present c. It is a financial liability designated as at FVTPL and the entity is
its financial statements in a currency which required to present the effects of changes in the liability’s credit risk
is different from its functional currency, then in OCI
it may do so by choosing the other currency d. It is a financial asset measured at Fair Value through Other
as its presentation currency and applying the Comprehensive Income (FVOCI) and the entity is required to
recognise some changes in fair value in OCI.
translation procedures as given in Ind AS 21.
3. This investment is not designated as a hedging instrument in a cash flow
hedge of an exposure to changes in foreign currency rates. Accordingly,
ITFG was of the view that it would not be covered within the exceptions
to the general principle enunciated in Ind AS 109 but would be measured
at FVTPL.
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Ind AS Implementation Guide I 90
ITFG considered the issue whether the foreign Further, Ind AS 109 does not contain any requirement
exchange difference is required to be presented for separation of change in fair value of a foreign-
separately from other fair value changes in the currency denominated financial asset measured at
statement of profit and loss. FVTPL into the two constituent parts (i.e. change in
fair value expressed in terms of foreign currency and
change in exchange rate).
Ind AS 21 specifically excludes financial
instruments measured at FVTPL from its Accordingly, in the given case, ITFG clarified that P Ltd
requirement of disclosure of the amount of the is not required to present change in fair value of the
amount of exchange differences recognised in investment in debentures on account of change in
profit or loss. relevant foreign exchange rate separately from other
changes in the fair value of the investment.
(ITFG 20, Issue 1)
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9. First-time adoption
of Ind AS
Summary
This chapter covers:
• Ind AS 101, First-time Adoption of Indian Accounting Standards
The 2013 Act mandates preparation of financial statements of specified companies in accordance
with Ind AS. For this purpose, the Ministry of Corporate Affairs (MCA) had laid down a road
map which provided guidance for adoption of Ind AS by the specified companies in a phased
manner. Ind AS 101 provides principles for transition and disclosures to be made in the financial
statements by a first-time adopter.
Key principles
• Ind AS 101 provides a suitable starting point for Accounting policies
entities that are transitioning to Ind AS. Ind AS 101
• An entity is required to use the same accounting
is applied by an entity in its first Ind AS financial
policies in its opening Ind AS balance sheet and
statements and each interim financial report, if
throughout all periods presented in its first Ind AS
any, that it presents in accordance with Ind AS 34,
financial statements.
Interim Financial Reporting.
• Accounting policies are required to be chosen
• The date of transition is the beginning of the earliest
from Ind AS effective at the end of its first Ind
comparative period presented on the basis of
AS reporting period, unless there is an explicit
Ind AS. At least one year of comparatives is also
exemption or option provided in Ind AS 101.
presented together with the opening balance sheet,
which is prepared at the date of transition to Ind AS. • An entity is required to take the following steps in its
opening Ind AS balance sheet:
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Ind AS Implementation Guide I 92
– Recognise all assets and liabilities whose opening Ind AS balance sheet should comply with
recognition is required by Ind AS each Ind AS:
– Not recognise items as assets or liabilities if Ind – Prohibits retrospective application of some
AS do not permit such recognition specific aspects of an Ind AS
– Reclassify items that it recognised in accordance – Grants exemptions from some specific
with previous GAAP as one type of asset, liability requirements of an Ind AS.
or component of equity, but are a different type Explanation of transition to Ind AS
of asset, liability or component of equity in
accordance with Ind AS, and • An entity is required to explain how the transition
from previous GAAP to Ind AS affected its reported
– Apply Ind AS in measuring all recognised assets balance sheet, financial performance and cash
and liabilities. flows.
• The accounting policies in the opening Ind AS Disclosures
balance sheet may differ from those that an entity
used for the same date under previous GAAP. The • Detailed disclosures on the first-time adoption of
resulting adjustments arising from events and Ind AS including reconciliations of equity and profit
transactions before the date of transition to Ind AS or loss from previous GAAP to Ind AS are required
are generally recognised in retained earnings. in the annual financial statements as well as some
disclosures in its interim financial statement.
• Ind AS 101 establishes the following two categories
of exceptions to the principle that an entity’s
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Guidance from ITFG clarifications foreign currency items to the cost of the related
PPE. At the time of transition to Ind AS if such an
entity decides to avail the deemed cost exemption
I. Clarifications with respect to the application of under paragraph D7AA of Ind AS 101, but does not
the deemed cost exemption elect to continue to capitalise foreign exchange
differences (also refer section II below), it would
As stated above, Ind AS 101 permits an entity
still be required to carry forward the entire previous
to measure items of PPE, investment property,
GAAP carrying amount for all of its PPE and would
intangible assets and investments in subsidiaries/
not be permitted to reverse the impact of paragraph
associates/joint ventures on the date of transition
46/46A of AS 11 from the deemed cost of PPE.
at either their fair value or their carrying amount
(ITFG 7, Issue 3)
in accordance with previous GAAP and use this
amount as a measure of their deemed cost. Subsequent to issuing the above clarification in
bulletin 7, the ITFG clarified (refer paragraph I (c)
The application of this optional exemption gives
below) that the deemed cost of an asset, being its
rise to several accounting issues, especially when
previous GAAP carrying amount, may be adjusted
considering the interaction of this exemption in
only to the extent of consequential adjustments
Ind AS 101 with the requirements of other Ind AS.
arising from the application of other Ind AS (ITFG 12,
These issues are further discussed below.
Issue 10).
a. Applicability of deemed cost exemption
c. Consequential adjustments to deemed cost,
Paragraph D7AA of Ind AS 101, provides an option being the previous GAAP carrying amount of
to a first-time adopter at the date of transition assets and liabilities
to continue with the carrying value of all PPE
An entity is required to recognise, classify and
(intangible assets or investment property) measured
measure assets and liabilities in its opening Ind AS
as per previous GAAP, and use it as its deemed cost
balance sheet in accordance with Ind AS.
without making any further adjustments based on
application of other Ind AS. Based on the above guidance, and subject to any
specific exemption/exception in Ind AS 101, all
Alternatively, Ind AS 101 also permits a first-time
assets and liabilities are required to be recognised in
adopter to elect to measure an item of PPE at the
accordance with the principles of Ind AS 101.
date of transition to Ind AS at its fair value and use
that fair value as its deemed cost on transition. This However, there may be situations where no
option may be applied selectively to some items of exemption/exception has been provided for an item
PPE. of asset and/or liability, and the application of Ind
AS principles to such an item has a corresponding
impact on another item of asset and/or liability
An entity is not permitted to continue with the
which is measured at its previous GAAP carrying
previous GAAP carrying value as deemed cost
amount at the transition date as permitted by Ind AS
on a selective basis for some of the items of PPE
101.
and use fair value as deemed cost approach for
the remaining items. (ITFG 5, Issue 3) In such a situation, the adjustment to the assets/
liabilities measured at deemed cost is only
consequential in nature and arises due to the
b. Reversal of the effects of paragraph 46/46A of application of the transition requirements of Ind
AS 11 under previous GAAP carrying amount of AS 101 to another item. Therefore, the previous
PPE on transition to Ind AS GAAP carrying amount may be adjusted only to the
An entity that would avail of deemed cost extent of consequential adjustments. Except such
exemption of paragraph D7AA (as mentioned in consequential adjustments, no further adjustments
above issue) would be required to carry forward should be made to the deemed cost (being the
the entire previous GAAP carrying amount for all of previous GAAP carrying amount) due to the
its PPE on transition to Ind AS. Ind AS 101 does not application of other Ind AS. (ITFG 12, Issue 10).
permit any further adjustments to the deemed cost
of PPE. This clarification may result in additional
adjustments being made to the deemed cost of
Under previous GAAP, an entity may have availed
PPE for items such as certain borrowing costs,
of the option under paragraph 46/46A of AS 11, The
hedging gains/losses, etc.
Effects of Changes in Foreign Exchange Rates to
capitalise foreign exchange differences on long-term
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This clarification is more general in nature, although though the PPE is measured at its deemed cost
clarifications have been provided in the past on specific (being previous GAAP carrying amount). (ITFG 5,
consequential adjustments – please refer paragraph I Issue 5)
(d) and (e) below: ii. Fair value as deemed cost: The entity may elect
d. Processing fees on loans to measure its PPE at fair value and use that as
An entity may have incurred processing fees on its deemed cost on the date of transition to Ind
a loan obtained before transition to Ind AS and AS in accordance with principles of Ind AS 101.
capitalised these as part of the relevant item of PPE Considering the principles in Ind AS 113, fair
in accordance with the previous GAAP. On transition value of the asset is the exit price that would be
to Ind AS, an entity may elect to apply the deemed received to sell the asset in an orderly transaction.
cost exemption and continue with the previous As fair value is a market-based measurement
GAAP carrying value for such PPE. and not an entity specific measurement, it is
independent of the government grant received
However, the loan is required to be measured at on the asset. Consequently, no adjustment with
amortised cost (in accordance with Ind AS 109) and regard to government grant should be made to
its carrying amount is to be restated to its amortised the fair value of the PPE, being the deemed cost
cost in accordance with Ind AS 109 as at the date of on the date of transition to Ind AS. However, the
transition. entity is required to recognise the asset related
As a consequence, in order to restate the carrying government grant outstanding on the transition
amount of loan, the deemed cost of the PPE, being date as deferred income in accordance with
its previous GAAP carrying amount at the date of the requirements of Ind AS 20. The resultant
transition, should be reduced by the amount of adjustments should therefore be made in
processing cost (net of cumulative depreciation retained earnings or if appropriate, another
impact). category of equity at the date of transition to Ind
This would be in the nature of consequential AS. (ITFG 12, Issue 2)
adjustment to enable an adjustment to the carrying Please refer chapter 10, Other topics-Accounting for
amount of loan as required by Ind AS. (ITFG 5, Issue Government Grants and Disclosure of Government
4) Assistance for more details on amended Ind AS 20
e. Government grants for purchase of a fixed asset (ITFG 17, Issue 1)
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Ind AS Implementation Guide I 98
under previous GAAP for exchange differences c. Amortisation of FCMITDA on transition to Ind AS
arising from translation of long-term foreign Ind AS 109 provides guidance on the measurement
currency monetary items recognised in the financial of financial liabilities classified into the amortised
statements for the period ending immediately cost category and requires the application of the
before the beginning of the first Ind AS financial Effective Interest Rate (EIR) method to measure
reporting period. amortised cost. The application of this method may
The application of this exemption in Ind AS 101 gives result in a change in the carrying amount of a long-
rise to several practical implementation issues, term foreign currency liability on transition to Ind AS,
which are highlighted below. as compared to previous GAAP.
a. Applicability of exemption under paragraph If an entity applies the exemption in paragraph
D13AA of Ind AS 101 D13AA of Ind AS 101 and continues to accumulate
The option (under Ind AS 101) to continue with foreign exchange gains or losses on translation of
the accounting policy under paragraph 46/46A of such an item in FCMITDA, the balance in FCMITDA
AS 11, is available for only those long-term foreign should be revised retrospectively on the basis of the
currency loans that were taken/drawn down before amortised cost of the liability (as determined under
the beginning of the first Ind AS reporting period i.e. Ind AS 109 on the date of transition). The revised
1 April 2017 for a company falling within phase 2 of balance of FCMITDA should be amortised over the
the Ind AS adoption road map. (ITFG 1, Issue 3) and balance period of that long-term liability through the
(ITFG 7, Issue 1) statement of profit and loss. (ITFG 2, Issues 1 and 6)
b. Exemption under paragraph D13AA of Ind AS d. Exemption under paragraph D13AA on change
101 vis-a-vis borrowing costs under Ind AS 23 in functional currency
In case of a first-time adopter of Ind AS which would When the functional currency of a company
present its first Ind AS financial statements for the changes from INR to any other currency (e.g. USD),
financial year 2018-19, ITFG considered and clarified then any loans taken in the new functional currency
on exchange differences that qualify as borrowing (USD) would not be considered as long-term foreign
costs as per paragraph 6(e) of Ind AS 23, Borrowing currency monetary items under previous GAAP
Costs. In the given scenario, the relevant entity ( i.e. paragraph 46A of AS 11)
was exercising the option provided in paragraph Therefore, an entity cannot continue to recognise
46/46A of AS 11 and intended to continue to follow the exchange differences arising from those loans,
the same accounting policy in accordance with in the cost of fixed assets under paragraph D13AA
paragraph D13AA of Ind AS 101. of Ind AS 101. (ITFG 1, Issue 4)
e. Accounting policy for exchange differences to
A first-time adopter of Ind AS can continue to long-term forward exchange contracts
apply an accounting policy based on para 46A of
Companies that availed of the option to apply
AS 11 upon transition to Ind AS. When a company
paragraph 46/46A of AS 11 under previous GAAP
applies paragraph 46A of AS 11 then it does not
may have also capitalised foreign exchange
apply AS 16, Borrowing Costs to those exchange
differences on forward exchange contracts (covered
differences relating to long-term foreign currency
by paragraph 36 of AS 11) acquired to hedge long-
monetary items that otherwise qualify as being in
term foreign currency loans. This was permitted in
the nature of adjustments to interest cost within
accordance with the clarification issued by ICAI in
the meaning of paragraph 4(e) of AS 16.
its Frequently Asked Questions (FAQs) on the AS 11
notification.
Therefore, ITFG clarified that a company which However, the exemption in paragraph D13AA of Ind
wishes to continue to avail of the exemption provided AS 101 relates only to foreign exchange differences
by paragraph D13AA of Ind AS 101 would not be on long-term foreign currency monetary items
permitted to apply paragraph 6 (e) of Ind AS 23 to recognised in the financial statements prior to the
that part of exchange differences on such long-term first Ind AS financial reporting period and would
foreign currency monetary items. (ITFG 18, Issue1). not apply to long-term forward exchange contracts.
(ITFG 7, Issue 4)
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Accordingly, ICAI clarified that the difference Although Ind AS 20 requires that the benefit of a
between the carrying amount of the financial liability government loan at a below-market rate of interest
(as per previous GAAP) on the date of transition and is treated as a government grant, such benefit
its amortised cost as on that date, computed as per (based on a retrospective restatement of the
the EIR method specified in Ind AS 109, should be loan amount at its fair value on initial recognition
adjusted by crediting the capital reserve account under Ind AS 109) would not be recognised for a
and the corresponding debit would be to the government loan existing at the date of transition,
relevant account which was credited earlier. (FAQ since Ind AS 101 does not permit such retrospective
dated 7 April 2017 issued by the ASB of ICAI). restatement.
A first-time adopter is required to use its previous
Companies that have previously adjusted GAAP carrying amount of government loan as the
the entire redemption premium against the Ind AS carrying amount on the date of transition.
securities premium account and recognised the It should apply the requirements of Ind AS 20
full repayable amount of the liability would be and Ind AS 109, prospectively to government
required to reverse the unamortised premium loans existing at the date of transition to Ind AS,
expense on transition to Ind AS. This would unless the necessary information needed to apply
subsequently be recognised as an interest the requirements of Ind AS 109 and Ind AS 20
expense through the statement of profit and retrospectively, has been obtained at the time of
loss over the remaining period until redemption. initially accounting for that loan. On prospective
This could have a significant impact on the application of Ind AS 109, the EIR of the loan
determination of future profits under Ind AS. should be computed by comparing the carrying
amount of the loan at the date of transition with the
amount and timing of expected repayment to the
e. Depreciation on first-time adoption government.
An entity, being a first-time adopter of Ind AS is Another important related issue is whether this
required by Ind AS 101 to measure its PPE on the exemption would apply to the deferment of a liability
date of transition either by retrospectively applying payable to government based on an agreement, i.e.
Ind AS 16 or at deemed cost (being either fair value liability similar to sales tax deferment for 10 years.
or previous GAAP carrying amount at the date of Often in such deferral schemes (e.g. where the
transition). amount of sales tax collected by an entity from its
If the entity elects to measure its PPE by customers is retained by the entity and is required
retrospective application of Ind AS 16, it is not to be repaid after a specified number of years) are
permitted to re-estimate its depreciation, unless its similar in nature to an interest-free loan. Hence, Ind
estimate of depreciation in the previous GAAP was AS 109 and Ind AS 20 should also be prospectively
in error. applied to such balances (e.g. deferred sales tax
liabilities) outstanding at the date of transition. (ITFG
However, when an entity has not estimated the
12, Issue 7).
useful life of its assets, but has depreciated its
assets as per the minimum requirements of law
(at the rates prescribed under Schedule XIV to the Entities are, therefore, not required to remeasure
Companies Act, 1956), then it would be required their deferred sales tax liabilities outstanding at
to re-compute the depreciation by assessing the the date of transition.
useful life of the asset in accordance with Ind AS 16.
(ITFG 3, Issue 14) g. . Business combination accounting in case of
acquisitions by first-time adopter
f. Accounting treatment of government loans at a
below-market rate of interest In the year 2009, an entity A Ltd. formed a
subsidiary B Ltd. by subscribing to 60 per cent of
Ind AS 101 requires a first-time adopter to apply
its share capital. Additionally, A Ltd. acquired 25 per
the requirements in Ind AS 109 and Ind AS 20
cent of share capital of B Ltd. during the month of
prospectively to government loans existing at the
October 2015. Subsequently, in the Financial Year
date of transition to Ind AS. Therefore, the carrying
(FY) 2017-18, A Ltd. transitioned to Ind AS with its
amount of government loan, under previous GAAP,
date of transition as 1 April 2017.
would continue to be recognised at the date of
transition to Ind AS.
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Ind AS Implementation Guide I 102
Subscribed Additional
A Ltd. 60 per cent B Ltd. A Ltd. B Ltd.
25 per cent
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Therefore, ITFG clarified that a first-time adopter Ind AS for the first time when it prepares its financial
does not have the choice of applying the simplified statements for the accounting period beginning on 1
transition method. (ITFG 19, Issue 3) April 2019.
i. Accounting of operating leases of a subsidiary In the year 2014, A Ltd. acquired an Indian company
not capitalised by a first-time adopter parent as its subsidiary. The acquisition qualifies as a
An entity A Ltd. is a first-time adopter of Ind AS. Its business combination as per Ind AS 103.
date of transition is 1 April 2018 and it would apply
Acquired in 2014
A Ltd. Subsidiary
(parent) Business combination (which was lessee)
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Summary
This chapter covers:
• Ind AS 1, Presentation of Financial Statements
• Ind AS 7, Statement of Cash Flows
• Ind AS 8, Accounting Policies, Changes in Accounting Estimates and Errors
• Ind AS 20, Accounting for Government Grants and Disclosure of Government Assistance
• Ind AS 23, Borrowing Costs
• Ind AS 24, Related Party Disclosures
• Ind AS 27, Separate Financial Statements
• Ind AS 33, Earnings per Share
• Ind AS 37, Provisions, Contingent Liabilities and Contingent Assets
• Ind AS 108, Operating Segments
• Applicability of Ind AS
• Other opinions by EAC
• Other EMs
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Key principles
• Ind AS 1 prescribes the basis for presentation of • A liability that is payable on demand because certain
general purpose financial statements1 to ensure conditions are breached is not classified as current
comparability both with the entity’s financial if the lender has agreed, after the reporting date but
statements of previous periods and with the before the financial statements are authorised for
financial statements of other entities. It sets out issue, not to demand repayment.
overall requirements for the presentation of both
Consolidated Financial Statements (CFS) and Schedule III to the Companies Act, 2013
Standalone Financial Statements (SFS), guidelines (2013 Act)
for their structure and their content. • On 1 October 2018, Ministry of Corporate Affairs
• Entities are required to prepare financial statements (MCA) through its notification has amended
on a going concern basis unless management Schedule III to the 2013 Act. The Schedule III to
intends to either liquidate the entity or to cease the 2013 Act provides general instructions for
trading, or has no realistic alternative but to do so. preparation of financial statements of a company
under both Accounting Standards (AS) and Ind AS
• The standard requires specific disclosures in the
Currently, Schedule III is divided into three divisions
balance sheet, the statement of profit and loss, or
as follows:
the statement of changes in equity and requires
additional disclosures (wherever required) to be – Division I: This is applicable to a company
made either in those statements or in the notes. whose financial statements are prepared in
accordance with AS.
• A statement of changes in equity (and related notes)
reconciles opening to closing amounts for each – Division II: This is applicable to a company
component of equity. whose financial statements are prepared in
accordance with Ind AS (other than Non-Banking
• All owner-related changes in equity are presented in
Financial Companies (NBFCs)2).
the statement of changes in equity separately from
non-owner changes in equity. – Division III: This is applicable only to NBFCs
which are required to prepare financial
• Generally, the entity presents its balance sheet
statements in accordance with Ind AS.
classified between current and non-current assets
and liabilities.
• An asset is classified as current if it is expected to
be realised in the normal operating cycle or within
12 months, it is held for trading or is cash or a cash
1. For entities operating in sectors such as banking, insurance, electricity,
equivalent.
etc., specific formats for presentation of financial statements may be
• A liability is classified as current if it is expected to prescribed, accordingly Ind AS 1 may not be applicable to that extent.
be settled in the normal operating cycle, it is due 2. NBFC means a NBFC as defined in Section 45-I(f) of the Reserve Bank
within 12 months, or there are no unconditional of India Act, 1934 and includes housing finance companies, merchant
banking companies, micro finance companies, mutual benefit companies,
rights to defer its settlement for at least 12 months.
venture capital fund companies, stock broker or sub-broker companies,
nidhi companies, chit companies, securitisation and reconstruction
companies, mortgage guarantee companies, pension fund companies,
asset management companies and core investment companies.
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Guidance from ITFG clarifications However, applying the same analogy in respect of
operating profit disclosure may not be appropriate
since certain items which are credited to the
Presentation and classification statement of profit and loss may not form part of
Presentation of operating profit as a separate line operating profit measure. As a result giving a separate
item not permitted line item for disclosure of the operating profit may
not be appropriate and would result in change in the
Division II of Ind AS based Schedule III requires
format of statement of profit and loss as prescribed by
disclosure of aggregate of ‘revenue from operations’
Division II of Schedule III.
and ‘other income’ on face of the statement of profit
and loss. Revenue from operations is to be separately Moreover, Division II of Schedule III and Ind AS 1
disclosed in the notes, showing revenue from: require classification of expense by nature and not
by function. The operating profit measure sub-total
• Sale of products (including excise duty)
may result in a more appropriate presentation of
• Sale of services and performance for entities classifying expenses by
• Other operating revenues. function, but such a classification of expenses by
The aggregate of ‘other income’ is to be disclosed function is not permitted. Therefore, a company would
on face of the statement of profit and loss. In not be able to present an operating profit measure
accordance with the Note 5 of general instructions for sub-total as part of the statement of profit and loss.
the preparation of statement of profit and loss ‘other However, the entity may provide such additional
income’ is required to be classified as: information in the financial statements. (ITFG 13, Issue
5)
• Interest income
Classification of interest related to delay in
• Dividend Income and payment of taxes
• Other non-operating income (net of expenses In accordance with Note 4 of the general instructions
directly attributable to such income). for the preparation of the statement of profit and loss,
Division II of Schedule III does not define the term Division II of Schedule III to the 2013 Act, the finance
‘other operating revenue’. Additionally, it does not costs are classified as below:
specifically require disclosure of ‘operating profit’. a. Interest
The ICAI issued a GN and according to the GN, ‘other b. Dividend on redeemable preference shares
operating revenue’ would include revenue arising c. Exchange differences regarded as an adjustment to
from a company’s operating activities, i.e., either its borrowing costs
principal or ancillary revenue- generating activities, but
which is not revenue arising from sale of products or d. Other borrowing costs (specify nature).
rendering of services. ITFG considered an issue related to payment of taxes
levied by a local authority. Interest was levied at a
variable rate ranging from one per cent to three per
Accordingly, an entity should decide classification cent per month depending upon the length of period
of an income based on the facts of each case of delay.
and detailed understanding of the company’s The above issue was considered from the perspective
activities. of classification of interest levied due to delay in
payment of taxes in the statement of profit and loss
i.e. whether it would form part of finance cost or
In addition, Schedule III to the 2013 Act sets out the would be classified as part of ‘other expenses’.
minimum requirements for disclosure in the financial In this case, local taxes not paid by due date represent
statements including notes. It states that line items, interest bearing liabilities. Therefore, it was clarified
sub-line items and sub-totals shall be presented as that the entity would need to evaluate whether
an addition or substitution on the face of the financial the interest payable for delay in payment of taxes
statements when such presentation is relevant to the is compensatory in nature for time value of money
understanding of the company’s financial position or or penal in nature. Thus, judgement is required to
performance or to cater to industry/sector-specific be exercised based on the evaluation of facts and
disclosure requirements, apart from, when required circumstances of each case.
for compliance with amendments to the 2013 Act or
Ind AS.
The GN illustrates certain financial measures e.g.
Earnings before Interest, Tax, Depreciation and
Amortisation (EBITDA) as an additional line item on
the face of the statement of profit and loss.
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On the basis of evaluation, if an entity concluded In accordance with Ind AS 1, presentation of true
that interest was compensatory in nature then and fair view requires the faithful representation
such interest would be required to be included of the effects of transaction, other events and
in finance cost. On the other hand, if interest on conditions in accordance with the definitions and
delayed payment of taxes was penal in nature, recognition criteria for assets, liabilities, income
then it would be classified as ‘other expenses’. and expenses set out in the Framework.
(ITFG 17, Issue 8)
(Please refer chapter 5, Income Taxes for a discussion ITFG clarified that in order to achieve fair presentation,
on the treatment of income tax related interest and appropriate accounting treatment would be to
penalties under Ind AS vis-à-vis IFRS (ITFG 16 Issue 2)) recognise contractual obligation for payment of
Classification of security deposits accepted by interest as well as the waiver thereof. Thus, Entity A
utility companies as current liabilities would be required to recognise interest as an expense
and the waiver thereof as an item of income. Further,
In one of the earlier ITFG clarifications, which was
the same would also require to be disclosed as related
subsequently withdrawn, items such as security
party transactions. (ITFG 22, Issue 7)
deposits accepted by utility entities were required
to be classified as ‘current liabilities’ since the
entities do not have the unconditional right to defer
their repayment for a period of 12 months after the
reporting date. This is regardless of whether an entity
expects to settle such deposits within this time frame.
This view was consistent with the view provided in
Opinions by EAC
the Education Material on Ind AS 1 issued by the Ind Classification of consumer deposit
AS committee of ICAI. However, previously, under repayable in full anytime at the time of
the Revised Schedule VI to the Companies Act, 1956, surrender of the connection by the entity
companies were permitted in specific cases based engaged in supply of liquid petroleum gas
on commercial practice (such as in the case of utility (LPG) to customers in cylinders4
companies) to classify security deposits collected as
Deposits to be considered as financial
non-current. Therefore, entities that have followed
liability
a different practice prior to Ind AS implementation
would need to evaluate presentation of such deposits. If in accordance with an agreement, a
customer could surrender the connection
Presentation and accounting treatment of waiver
anytime and an entity is obliged to repay
of interest on the loan taken
the full deposit amount, then there is a
The ITFG considered an issue related to the contractual obligation to deliver cash in
accounting treatment of interest on the loan for the terms of guidance contained in Ind AS 32,
year 2018-19. Financial Instruments irrespective of the type
An entity A has an outstanding loan as at the year of customers. Accordingly, such deposits
end 2018-19 in its Ind AS financial statements. The should be classified as financial liability by
outstanding loan (repayable on demand and not the company.
related to a qualifying assets) was taken from one of Classification as current/non-current
its directors during the year 2015-16. In previous years,
In accordance with guidance contained
the interest was charged and paid to the directors.
in Ind AS 1, if an entity does not have an
However, in respect of interest on the loan for the
unconditional right to defer the settlement of
year, 2018-19, a waiver was obtained from the director
a liability beyond 12 months then the same
without amendment of the loan agreement.
should be classified as current liability.
ITFG noted that entity A is contractually obligated to
Further, General Instructions for Preparation
pay interest on the loan obtained from the director but
of Balance Sheet Under Division II - Ind AS
the same has been waived off in the current year.
Schedule III to the 2013 Act provides similar
definition of the current liability.
4. EAC Opinion published in the October 2019 edition of the Journal ‘The
Chartered Accountant’
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Ind AS Implementation Guide I 114
In this case, the company is required to refund Disclosure of impairment loss on long-term
the deposits as and when the connection is investments as an exceptional item6
surrendered by the customer and do not have an The EAC deliberated the topic of disclosure of
unconditional right to defer such settlement. The impairment loss on long-term equity investments
EAC clarified that such deposits received from in the joint venture and the associate as an
customers should be classified as current liability. exceptional item on the face of the statement of
Additionally, for better presentation and profit and loss.
disclosure, it was suggested that the company In the given situation, the investments in the joint
disclose the amount expected to be recovered or venture and associate are accounted for at cost
settled after more than 12 months for each asset in the SFS of the entity in accordance with Ind
and liability. AS 27. Accordingly, these are outside the scope
Disclosure of government grants5 of Ind AS 109, and their impairment would be in
Grant of funds is a government grant accordance with Ind AS 36.
It was clarified that the government grants (being Further, EAC clarified that Ind AS 36 does not
receipts from a source other than shareholders) deal with presentation of impairment loss in
should not be recognised in equity. Rather, it the statement of profit and loss rather merely
should be recognised in statement of profit requires, inter alia, disclosure of the line item(s)
and loss in appropriate periods. Further, Ind of the statement of profit and loss in which the
AS 20, Accounting for Government Grants and impairment losses are included. On the other
Disclosure of Government Assistance requires hand, though, Ind AS 1 requires, inter alia,
all government grants to be recognised in the presentation of impairment losses (including
statement of profit and loss on a systematic basis reversals of impairment losses or impairment
over the periods in which the entity recognises as gains) determined in accordance with Section
expenses the related costs for which the grant is 5.5 of Ind AS 109 as a line item, it does not
intended to compensate. Ind AS 20 is based on specify a similar requirement for presentation of
the income approach. impairment losses determined in accordance with
Ind AS 36.
Accordingly, the unamortised portion of the grant
represents unfulfilled obligation which is expected Additionally, Division II to the 2013 Act does not
to result in outflow of resources in future (even specify impairment loss either as a separate line
though the same may not be refundable in future) item in the statement of profit and loss or as part
and thus it meets the definition liability. of any other line item.
Therefore, it was clarified that the government Hence, EAC clarified that only if the impairment
grant should be classified and presented under loss on long-term investments is material, it
the head ‘non-current liabilities’ and ‘current should be disclosed separately. It quoted that an
liabilities’ in the balance sheet in accordance item in Ind AS 1 para 98(a) represents impairment
with the requirements of the Schedule III to the of inventories and property, plant and equipment
2013 Act as well as Ind AS 1.(The requirements and also reversals of such write-downs. These
of classification as current/non-current liability of items are examples only. The EAC mentioned that
both the Schedule III to the 2013 Act as well as impairment of long-term investments should also
Ind AS 1 are similar). be disclosed, if material, as required by Ind AS 1
para 98.
Additionally, the above classification and
presentation would be continued till the same Further, in the given situation, assuming that
is recognised in the statement of profit and loss impairment loss is both material and expected
on a systematic basis over the periods in which not to occur regularly, the long-term equity
the company would recognise as expenses investments could be presented on the face of
the related costs which are intended to be the statement of profit and loss as below:
compensated by the grant. • Exceptional item or
• Part of exceptional items (if there is any other
exceptional item) with disclosure of individual
items in the notes to accounts.
5. EAC Opinion published in the September 2019 edition of the Journal 6. EAC Opinion published in the September 2018 edition of the Journal
‘The Chartered Accountant’ ‘The Chartered Accountant’
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Ind AS Implementation Guide I 116
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Key principles
• Ind AS 7 requires an entity to provide information • The effect of exchange rate changes on cash and
about historical changes in its cash and cash cash equivalents held or due in a foreign currency
equivalents in a statement of cash flows1 which is reported in the statement of cash flows in order
classifies cash flows during the period into those to reconcile cash and cash equivalents at the
from operating, investing and financing activities. beginning and the end of the period.
• Cash comprises cash on hand and demand • An entity is required to disclose the components
deposits. Cash equivalents are short-term highly of cash and cash equivalents and present a
liquid investments that are readily convertible to reconciliation of the amounts in its statement of
known amounts of cash and which are subject to an cash flows with equivalent items reported in the
insignificant risk of changes in value. balance sheet.
• Cash and cash equivalents for the purposes of the • Additionally, it is required to disclose, together
statement of cash flows include certain short-term with a commentary by management, the amount
investments and in some cases, bank overdrafts. of significant cash and cash equivalents which are
• The statement of cash flows presents cash flows restricted for specific purposes.
during the period, classified by operating, investing • An entity is required to provide disclosures that
and financing activities. enable users of financial statements to evaluate
• The entity presents its cash flows in the manner changes in liabilities arising from financing activities,
most appropriate to its business. including both changes arising from cash flows and
non-cash changes.
• Taxes paid are separately disclosed and classified
as operating activities unless it is practicable to • Accordingly, an entity is required to disclose the
identify them with, and therefore, classify them as, following changes in liabilities arising from financing
financing or investing activities. activities:
• Cash flows from operating activities may be – Changes from financing cash flows,
presented under either the direct method or the – Changes arising from obtaining or losing control
indirect method.2 of subsidiaries or other businesses,
• Generally, all financing and investing cash flows are – The effect of changes in foreign exchange rates,
reported gross. Cash flows are offset only in limited – Changes in fair values and
circumstances.
– Other changes.
• Foreign currency cash flows are translated at the
exchange rates at the date of the cash flows (or The above disclosures also apply to changes in
using averages when appropriate). financial assets (for example, assets that hedge
liabilities arising from financing activities) if cash
• Unrealised gains and losses arising from changes in flows from those financial assets were, or future
foreign currency exchange rates are not cash lows. cash flows will be included in cash flows from
financing activities.
1. The 2013 Act defines the term ‘financial statements’ to include cash 2. In case of listed entities, the Securities and Exchange Board of India
flow statement for the financial year. Therefore, preparation of cash flow (Listing Obligations and Disclosure Requirements) Regulations, 2015
statements is mandatory under the 2013 Act. However, its preparation require the use of the indirect method in preparing the cash flow
would be in accordance with the requirements of this standard. statement. Additionally, SEBI has mandated disclosure of cash flow
Additionally, in case of a one person company, small company and dormant statement on a half yearly basis for all listed entities for financial results
company, financial statements may not include the cash flow statement. from 1 April 2019.
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Ind AS Implementation Guide I 118
Guidance from ITFG clarifications primarily due to changes in interest rates. Therefore,
ITFG clarified that the amount of cash that would be
received from redemption or sale of the units could
Classification of investments made in be known at the time of the initial investment and
units of money-market mutual funds as the value of such units could be subject to a more
cash equivalents insignificant risk of change during the period of their
holding.
Ind AS 7 prescribes the following three cumulative
conditions, which are to be met for an investment to However, there could be situations wherein this last
be classified as a ‘cash equivalent’: condition could be met for instance, units of money-
market mutual funds have been acquired for a very
i. The investment must be for meeting short-term
brief period before the end of tenure of a mutual fund
cash commitments
and the maturity amounts of the mutual funds are
ii. It must be highly liquid, i.e. readily convertible to pre-determined and known. In such a case, it could
cash be argued that the redemption amount of the units is
iii. The amount that would be realised from the known and subject only to an insignificant change in
investment must be known, with no more than value. (ITFG 16, Issue 4)
an insignificant risk of change in value of the
investment.
An assessment of the above mentioned three
cumulative conditions is required to classify
investment in units of money-market mutual funds4 as
cash equivalents under Ind AS. The assessment is as
follows:
• Investment must be for meeting short-term cash
commitments: Whether an investment has been
held for meeting short-term cash commitments
depends on the management’s intent which could
be evidenced from documentary sources such as
investment policy, investment manuals, etc. It could
also be corroborated by the actual experience of
buying and selling those investments. However,
such investments should be held only as a means
of settling liabilities, and not as an investment or
for any other purposes. Therefore, this condition
requires an assessment of facts and circumstances
of each case.
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119
8 Guidance and examples of cash flows arising from taxes on income and whether the same
should be separately disclosed under cash flows from investing or financing activities
9 Guidance on examples of cash flows which can be reported on a net basis
10 Guidance on the preferred method to report cash flows from operating activities
12 Guidance on classification of interest and dividend paid and presentation of lease payments
under finance lease and acquisition of a fixed asset on deferred payment basis
13 Guidance and examples of cash and cash equivalent balances held by the entity that are not
available for use
14 Illustrative examples where reconciliation statement is required to be disclosed between the
amounts in the statement of cash flows with the equivalent items reported in the balance sheet
15 Guidance on reporting of sale proceeds from a sale and leaseback transaction
17 Guidance on presentation of cash flows arising out of payments for manufacture or acquisition
of assets held for rental to others and subsequently held for sale in the ordinary course of
business
18 Guidance on whether comparative figures are required to be presented in the statement of
cash flows
19 Guidance on classification of purchase and sale of securities in the statement of cash flows
20 Guidance on classification of cash receipts and payments arising out of future contracts,
forward contracts, option contracts and swap contracts
21 Guidance on treatment of interest income in the statement of cash flows from bond over the
period of bond by an entity which is not in the business of dealing in securities
22 Guidance and examples on disclosure of non-cash transactions in the financial statements
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Ind AS Implementation Guide I 120
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Key principles
• Ind AS 8 prescribes the criteria for selecting and • A change in depreciation method used by an entity
changing accounting policies, together with the should reflect the pattern in which the asset’s future
accounting treatment and disclosure of changes economic benefits are expected to be consumed by
in accounting policies, changes in accounting the entity. A change in depreciation method would
estimates and corrections of errors. be accounted for as a change in an accounting
• Accounting policies are the specific principles, estimate of the entity.
bases, conventions, rules and practices applied • The effect of change in an accounting estimate is
by an entity in preparing and presenting financial required to be recognised prospectively by including
statements. it in profit or loss in the period of the change, if it
• Ind AS 8 prescribes a two-step approach in selection affects that period only or the period of the change
and application of the accounting policies – when an and future periods, where it affects both.
Ind AS specifically covers a particular issue then an • Prior period errors are omissions from, and
accounting policy is determined by applying the Ind misstatements in, an entity’s financial statements
AS and in the absence of an Ind AS, an entity applies for one or more prior periods.
judgement based on the hierarchy of accounting • Errors include the effects of mathematical mistakes,
literature. mistakes in applying accounting policies, oversights
• An entity is required to select and apply the or misinterpretations of facts, and fraud.
accounting policies consistently for similar • When it is impracticable to determine either the
transactions, other events and conditions, period specific effects or the cumulative effect
unless an Ind AS specifically requires or permits of the error, Ind AS 8 requires to correct material
categorisation of items for which different policies prior period errors retrospectively in the first set of
may be appropriate. If an Ind AS requires or permits financial statements approved for issue after their
such categorisation, an appropriate accounting discovery by:
policy should be selected and applied consistently
to each category. – Restating the comparative amounts for the prior
period(s) presented in which the error occurred
• An entity is permitted to change an accounting or
policy only if the change is required by an Ind AS or
results in the financial statements providing reliable – If the error occurred before the earliest prior
and more relevant information. period presented, restating the opening balances
of assets, liabilities and equity for the earliest
• In case an entity has not applied a new Ind AS prior period presented.
that has been issued but is not yet effective, it is
required to disclose this fact along with known • Omissions or misstatements of items are material if
or reasonably estimable information relevant to they could, individually or collectively, influence the
assessing the possible impact that application of economic decisions that users make on the basis of
the new Ind AS will have on the entity’s financial the financial statements.
statements in the period of initial application.
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Ind AS Implementation Guide I 122
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123
14 Guidance on disclosure requirements for new or revised Ind AS which have been notified by the
MCA but are not yet effective.
(Refer ITFG 8, Issue 2)
15 Examples of changes in accounting estimates
17 Guidance on whether change in the depreciation method for an item of PPE a change in
accounting policy or a change in accounting estimate
18 Guidance on whether a parent entity needs to align the depreciation method(s) applied by its
subsidiaries in their SFS with its own depreciation method(s) in the CFS
19 Guidance on disclosures to be made in respect of changes in accounting estimates
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Ind AS Implementation Guide I 124
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Key principles
• Ind AS 20 is applied in accounting for and in incurred or for the purpose of giving immediate
the disclosure of government grants and in the financial support to the entity with no future related
disclosure of other forms of government assistance. costs shall be recognised in profit or loss of the
• Government grants, including non-monetary period in which it becomes receivable.
grants at fair value, are not recognised until there Presentation of government grant related
is reasonable assurance that the entity will comply
to assets
with the conditions attached to them and the grants
will be received. • Government grants related to assets, including
non-monetary grants at fair value, are presented
• A forgivable loan from government is treated as
in the balance sheet either by setting up the grant
a government grant when there is reasonable
as deferred income or by deducting the grant in
assurance that the entity will meet the terms for
arriving at the carrying amount of the asset (net
forgiveness of the loan.
presentation).
• The benefit of a government loan at a below-market
• There are two methods of presentation of the
rate of interest is treated as a government grant.
government grants related to assets as follows:
• In case of a government grant which is in the form
– One method recognises the grant as deferred
of transfer of a non-monetary asset (such as land
income that is recognised in profit or loss on a
or other resources), both the grant and asset are
systematic basis over the useful life of the asset.
accounted for at fair value of the non-monetary
asset. There is an alternate method for accounting – Another method is to deduct the grant in
for such non-monetary grants i.e. an entity may calculating the carrying value of the asset.
record both the asset and the grant at a nominal Thus, the grant would be recognised in the
amount rather than at fair value.2 statement of profit and loss over the useful life
of a depreciable asset as a reduced depreciation
Recognition of government grant expense.
• Government grants shall be recognised in profit or
Presentation of government grant related
loss on a systematic basis over the periods in which
the entity recognises as expenses the related costs to income
for which the grants are intended to compensate. • Grants related to income are presented as part of
• A government grant that becomes receivable profit or loss, either separately or under a general
as compensation for expenses or losses already heading such as ‘other income’ or alternatively, they
are deducted in reporting the related expenses.
1. MCA amended Ind AS 20 on 20 September 2018 and the amendments are 2. MCA notification dated 20 September 2018.
effective retrospectively from 1 April 2018
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Ind AS Implementation Guide I 126
Significant differences from IFRS3 • In case it concludes that the contribution is in the
nature of ‘shareholder contribution’, then Ind AS
• MCA amended Ind AS 20 and the amendments 20 would not apply, since it specifically scopes out
are effective retrospectively from 1 April participation by the government in the ownership
2018. Consequently, there are no significant of an entity. Thus, in accordance with Ind AS 101,
differences in Ind AS 20 as compared with IAS the entity is required to reclassify the contribution
20, Accounting for Government Grants and received, from capital reserve to an appropriate
Disclosure of Government Assistance. category under ‘other equity’ at the date of
transition.
The above principles would also apply for contributions
3. Indian Accounting Standards (Ind AS): An Overview (Revised 2019) received by an entity subsequent to the Ind AS
issued by ICAI transition date. (ITFG 9, Issue 3)
Guidance from ITFG clarifications Subsequent to the issue of the above clarification,
MCA has revised Ind AS 20 as well as made
consequential amendments to certain other Ind AS
Accounting for grants (e.g. Ind AS 12, Ind AS 16, Ind AS 40, etc.) and the
Accounting treatment for grants in the nature of amendments are effective from 1 April 2018. Going
promoters’ contribution forward, the principles for presentation of government
Accounting Standard (AS) 12, Accounting for grants related to assets as well as those related to
Government Grants, requires grants received repayment of government grants are to be applied as
with respect to an entity’s total investment or per the amended Ind AS 20.
total capital outlay, for which no repayment was
ordinarily expected (i.e. grants in the nature of
promoter’s contribution), to be credited directly to the
shareholders’ funds.
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127
Accounting of non-monetary asset grant recognising government grant and the related asset
As explained above Ind AS 20 has been recently at fair value.
amended. It now provides an entity with a choice As Ind AS 20 has been amended recently,
for accounting of government grants in the form of therefore, an issue may arise whether for the
non-monetary assets. Accordingly, an entity can either financial year 2018-19, X Ltd. is required or
present the non-monetary asset and grant at fair value permitted to change its accounting policy relating to
or record both asset and grant at a nominal amount. government grant.
In a scenario, X Ltd., a government company4 in In accordance with Ind AS 8, an entity would change
which 100 per cent of its paid-up capital is held by the an accounting policy only if the change:
Government of India, received certain land in the year 1. Is required by an Ind AS or
2008 from the government to construct and operate a
2. Results in the financial statements providing reliable
Mass Rapid Transit System (MRTS) in a metropolitan
and more relevant information about the effects
city. The land was received free of cost subject to
of transactions, other events or conditions on the
compliance with specified terms and conditions. In
entity’s financial position, financial performance or
accordance with the then applicable AS 12, the land
cash flows.
was recorded at a nominal value of INR1.
Following is the accounting of land under Ind AS:
i. X Ltd. is a first-time adopter of Ind AS and its first Due to the amendment of Ind AS 20, entities
Ind AS reporting period is financial year 2018-19 are not required to change the accounting policy
relating to the grant in preparing its financial
X Ltd. has a choice of recognising the grant and statements for the previous financial year.
the asset (i.e. land in this case), initially either at fair However, the entity is permitted to change its
value or at a nominal amount. accounting policy voluntarily.
Ind AS 101 further states the following with respect
to opening Ind AS balance sheet:
1. An entity is required to prepare and present an Ind AS 8 lays down following two requirements that
opening Ind AS balance sheet at the date of must be complied with in order to make a voluntary
transition to Ind AS. change in an accounting policy:
2. An entity is required to use the same accounting 1. The information resulting from application of the
policies in its opening Ind AS balance sheet changed (i.e. the new) accounting policy must be
and throughout all periods presented in its first reliable.
Ind AS financial statements. Those accounting 2. The changed accounting policy must result in
policies would comply with each Ind AS effective ‘more relevant’ information being presented in the
at the end of its first Ind AS reporting period. financial statements.
Generally, those accounting policies are applied
on a retrospective basis. Whether a changed accounting policy results in
reliable and more relevant financial information is a
Accordingly, X Ltd. is required to apply the amended matter of assessment based on the particular facts
Ind AS 20 for all periods presented in its financial and circumstances of each case.
statements for the financial year 2018-19, including
in preparing its opening Ind AS balance sheet as at 1 In order to ensure that such an assessment is made
April 2017. judiciously (a voluntary change in an accounting policy
does not effectively become a matter of free choice),
Additionally, under Ind AS 101, there is no mandatory Ind AS 8 further requires an entity making a voluntary
exception or voluntary exemption from retrospective change in an accounting policy to disclose, inter alia,
application of Ind AS 20. Consequently, X Ltd. is the reasons why applying the new accounting policy
required to apply the requirements of Ind AS 20, provides reliable and more relevant information.
retrospectively at the date of transition to Ind AS (and
consequently in subsequent accounting periods). In accordance with the above, ITFG clarified that X
Ltd. could make a voluntary change in accounting
ii. X Ltd. is not a first time adopter of Ind AS and policy provided if such a change results in its financial
financial year 2018-19 is its second (or third) statements providing reliable and more relevant
reporting period under Ind AS information about the effects of transactions, other
As X Ltd. transitioned to Ind AS a few years back, events or conditions on its financial position, financial
therefore it is following an accounting policy of performance or cash flows. (ITFG 17, Issue 1)
4. It is pertinent to note here that Ind AS 20 specifically scopes out the participation by the government in the ownership of an entity. In this fact pattern, the
Government of India has 100 per cent shareholding in the entity, but it has been assumed that the land provided has been evaluated as not being in the nature
of owners’ contribution and hence, it is in the nature of a government grant as per Ind AS 20.
Further, it has also been assumed that the above arrangement has been evaluated as not being within the scope of Appendix D, Service Concession
Arrangements of Ind AS 115 or scope of Appendix A, Service Concession Arrangements of Ind AS 18 as the case may be.
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129
Borrowing Costs1
Borrowing costs that are directly attributable to the acquisition, construction or production of a
qualifying asset form part of the cost of that asset. Other borrowing costs are recognised as an
expense.
1. MCA has amended Ind AS 23 on 30 March 2019. The amendment clarifies that in computing the capitalisation rate for funds borrowed generally, an entity
should exclude borrowing costs applicable to borrowings made specifically for obtaining a qualifying asset, only until the asset is ready for its intended use or
sale. Borrowings costs related to specific borrowings that remain outstanding after the related qualifying asset is ready for its intended use or for sale would
subsequently be considered as part of the general borrowing cost of the entity.
2. Ind AS 116, Leases supersedes Ind AS 17, Leases for annual reporting periods beginning on or after 1 April 2019.
3. Indian Accounting Standard (Ind AS): An overview (Revised 2019) issued by ICAI.
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Clarifications with respect to application of the The value of CWIP and timing of incurrence of
exemption to continue with the accounting policy the aforesaid expenditure should be determined
under para 46A of AS 11 from the perspective of PQR Ltd. and not from the
For further details on the exemption under paragraph perspective of ABC Ltd. Consequently, in separate
D13AA of Ind AS 101 vis-a-vis borrowing costs under and consolidated financial statements of PQR Ltd.,
Ind AS 23, please refer chapter 9, First-time adoption INR120,000 would represent the expenditure incurred
of Ind AS (ITFG 18, Issue 1) by PQR Ltd. on the CWIP and for purposes of applying
the requirements of Ind AS 23 relating to capitalisation
Application of capitalisation rate for assets
of borrowing costs.
acquired under business combination
Scenario II: ABC Ltd. is not merged into PQR Ltd.
ITFG considered a scenario where ABC company has
Capital Work in Progress (CWIP) of INR100,000 which Aquires
meets the definition of a ‘qualifying asset’ as per Ind PQR Ltd. 100% ABC Ltd.
AS 23 and capitalised corresponding borrowing cost
using capitalisation rate for general borrowings.
The issue raised to ITFG was what would be the
accounting treatment of borrowing cost in following
two situations:
i. ABC Ltd. merges with PQR Ltd., an independent
entity
ii. PQR Ltd. acquires 100 per cent shares and control Where PQR Ltd. acquires 100 per cent shares and
of ABC Ltd. but ABC Ltd. remains as a separate consequently control of ABC Ltd. which continues
legal entity which is consolidated by PQR Ltd. to remain in existence. PQR Ltd.’s consolidated
ITFG considered the issue and discussed the financial statements would include the CWIP as an
accounting of borrowing cost in two following asset but not in its separate financial statements. For
situations: the purpose of consolidated financial statements,
the determination of whether an asset meets the
Scenario I: ABC Ltd. is merged into PQR Ltd.
definition of a ‘qualifying asset’ and assessment of the
amount of expenditure incurred thereon would made
from the perspective of the group rather than from the
perspective of the subsidiary which owns or holds the
CWIP.
In the issue under consideration, the group has
incurred an expenditure of INR120,000 to acquire the
CWIP from a party outside the group. For the purpose
ABC Ltd. PQR Ltd. of applying the requirements of Ind AS 23 relating to
capitalisation of borrowing costs at the group level, it
Merged is determined that the CWIP meets the definition of
‘qualifying asset’ from the group’s perspective and
the amount of expenditure on the CWIP would be
considered to be INR120,000.
While the separate financial statements of PQR Ltd.
ITFG clarified that where ABC Ltd. is merged into PQR would include the investment in ABC Ltd. rather than
Ltd. and merger meets the definition of a ‘business individual assets and liabilities of ABC Ltd.
combination’ as per Ind AS 103, the CWIP would
appear as an asset in the separate (and consequently,
in the consolidated) financial statements of PQR Ltd. As investment is a financial asset SFS, borrowing
At the time of merger, PQR Ltd. needs to make a costs cannot be capitalised as part of carrying
fresh, independent assessment to evaluate whether amount as per the requirements of Ind AS 23
CWIP meets the definition of a qualifying asset from which specifically provides that financial assets
its perspective. are not qualifying assets. (ITFG 19, Issue 4)
In the given case, PQR Ltd made independent
assessment and asserted that the CWIP still meets
the definition of a qualifying asset and attributed an
amount of INR120,000 as a consideration towards
purchase of the CWIP as part of the purchase price.
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Ind AS Implementation Guide I 132
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133
Key principles
• A related party is a person or an entity that is
related to the entity that is preparing its financial Significant differences from IFRS1
statements.
• In India, the accounting standards cannot
• Key Management Personnel (KMP) are those override legal/regulatory requirements and
persons that have authority and responsibility for therefore, disclosures which conflict with
planning, directing and controlling the activities of confidentiality requirements of statute/
the entity, directly or indirectly, including any director regulations would not be disclosed. For
(whether executive or otherwise) of that entity. example, banks are obliged by law to maintain
• KMP and their close family members are also confidentiality in respect of their customers’
parties related to the entity. transactions and this standard would not
override the obligation to preserve the
• Related party relationships include those involving
confidentiality of their customers’ dealings.
control (direct or indirect), joint control or significant
influence • In Ind AS 24, the ‘definition of close members
of the family of a person’ has been amended
• A related party transaction is a transfer of resources,
to include brother, sister, father and mother in
services or obligations between a reporting entity
the category of family members who may be
and a related party, regardless of whether a price is
expected to influence, or be influenced.
charged.
• Relationships between a parent and its subsidiaries
are required to be disclosed irrespective of whether
1. Indian Accounting Standards (Ind AS): An Overview (Revised 2019) issued
there have been transactions between them. by ICAI.
• Comprehensive disclosures of related party
transactions are required for each category of
related party relationships.
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Ind AS Implementation Guide I 134
Guidance from ITFG clarifications S Ltd. is a public utility (being engaged in distribution
of electricity), but it is also a subsidiary of P Ltd. Thus,
there is a dual relationship between S Ltd. and P Ltd.
Disclosure of sitting fees paid to independent and as below:
non-executive directors i. A supplier and consumer
AS 18, Related Party Disclosures, does not include ii. Subsidiary and holding (which is a relationship
non- executive directors within the definition of covered within the related party relationships to
‘directors’. Ind AS 24 has brought independent and which the disclosure requirements of Ind AS 24
non-executive directors also within its scope by would apply).
including them in the definition of KMP.
Consumer of electircity
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135
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Ind AS Implementation Guide I 136
Guidance from ITFG clarifications AS 101 provides an exemption to measure the cost
of such an investment at either the cost determined
in accordance with Ind AS 27 or at a ‘deemed cost’
Accounting of profit share from Limited Liability based on its fair value at the date of transition to Ind
Partnerships (LLPs) AS or its previous GAAP carrying amount.
An entity may have a joint control over an LLP, which
is assessed as a joint venture. The entity should
account for its investment in the joint venture in its Above requirements of Ind AS 27 and the
SFS in accordance with Ind AS 27, i.e. either at cost exemption in Ind AS 101 would only apply to
or in accordance with Ind AS 109. Therefore, an those investments in a subsidiary, which meets
adjustment of profit share from LLP to the carrying the definition of an equity instruments under
amount of the investment in LLP in its SFS is not Ind AS 32 (from the issuer, i.e. the subsidiary’s
permitted. Accounting of return on investment (i.e. perspective).
profit share from LLP) would depend on the terms
of contract between the entity and LLP. The share in
profit in LLP should be recognised as an income in the Hence, if the debentures are classified as a financial
statement of profit and loss as and when the right to liability by the subsidiary, the holding company would
receive its profit share is established. (ITFG 5, Issue 8) have to classify its investment as a financial asset and
account for it under Ind AS 109. (ITFG 7, Issue 8)
Deemed cost of an investment in a subsidiary
Measurement of investment in subsidiaries, joint
ventures and associates at the end of the first Ind
An entity may elect to apply the deemed cost AS financial reporting period
exemption on transition to Ind AS and accordingly Please refer chapter 9, First time Adoption of Ind AS
measure its investment in its subsidiary at its fair for further details on measurement of investment in
value on the date of transition. Ind AS 27 permits subsidiary, associates and joint ventures (ITFG 11,
such an entity to measure its investment in its Issue 4)
subsidiary at either its cost or in accordance with
Accounting by issuer of financial guarantee
Ind AS 109 (i.e. at fair value) in its SFS.
Please refer chapter 3, Financial instruments for
further details on accounting of financial guarantee by
An entity may have used fair value as the the issuer (ITFG 16, Issue 1)
measurement basis for the deemed cost on transition.
Demerger of business divisions between unrelated
Post transition, the entity would continue to carry its
companies within the same group
investment in the subsidiary at the transition date fair
value, which is deemed to be its cost under Ind AS. The ITFG considered a situation where a company
(ITFG 3, Issue 12) (X Ltd.) had invested in two operating companies
(A Ltd. and B Ltd.), such that both the companies
(Please refer chapter 9, First time Adoption of Ind AS
were its associates, but were not under common
for further details on deemed cost of an investment in
control within the meaning of Ind AS. X Ltd. carries
a subsidiary) (ITFG 3, Issue 12)
its investments in associates at cost in its separate
Investments in debentures of a subsidiary financial statements.
company
Parent companies may often invest in the debentures
of its subsidiary companies. Such investments may Continuing
be in addition to their investment in respective shares business
of subsidiary. Practical implications arise regarding
accounting of such investments under the provisions
of Ind AS 27 and the consequent exemptions in
A Ltd.
paragraph D15 of Ind AS 101 at the time of transition Demerged
to Ind AS. X ltd.
business
It is noteworthy that Ind AS 109 is not applicable to B Ltd.
interest in subsidiaries, associates and joint ventures
that are accounted for in accordance with Ind AS 110,
Ind AS 27 or Ind AS 28.
As explained earlier, Ind AS 27 permits an entity to
account for its investments in subsidiaries, associates
or joint ventures either at cost or in accordance with
Ind AS 109 in its SFS. In addition, paragraph D15 of Ind
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137
As part of a proposed transaction, A Ltd. would In view of the above, ITFG drew analogy from:
demerge an identified business undertaking a. Paragraph 2(b) of Ind AS 103, which states that
(representing one or more business divisions), which Ind AS 103 does not apply to the acquisition of an
would vest in B Ltd. As a result, A Ltd. would continue asset or a group of assets that does not constitute
to survive as a separate legal entity with some of a business. In such cases, the cost of assets
its other business divisions. The consideration for purchased should be allocated to the individual
the demerger would be determined on the basis of identifiable assets and liabilities on the basis of their
the fair value of the underlying business, and would relative fair values at the date of purchase.
be issued in the form of fresh shares of B Ltd. to all
b. Principles of Ind AS 115, Revenue from Contracts
shareholders of A Ltd. (including to X Ltd.). The query
with Customers, which require use of standalone
related to the accounting treatment of a demerger
selling prices to allocate the transaction price
in the separate financial statements of X Ltd., which
to each performance obligation identified in a
measures investments in associates at cost.
customer contract.
The ITFG noted that the two principal issues to be
In accordance with the above, the carrying amount of
determined in the present case were:
X Ltd.’s investment in A Ltd. would be split between
a. What amount should be derecognised (to give the demerged business undertaking and business
accounting effect of the potential reduction in retained by A Ltd. on the basis of the relative fair
value of shares held in A Ltd. due to transfer of its values of the two. On demerger, the portion of
business division), and carrying amount allocated to the demerged business
b. What amount should be recognised (to give would be derecognised.
effect to the accounting treatment for the receipt Amount to be recognised
of additional shares of B Ltd. pursuant to the
In the current case, X Ltd. has adopted an accounting
demerger)?
policy of recognising investment in associates at
Amount to be derecognised ‘cost’. Since Ind AS 27does not define cost, the cost
Prior to demerger, X Ltd.’s investment in the shares of of additional shares in B Ltd. may be represented
A Ltd. represented its interest in both the demerged either by their fair value or by the (allocated) carrying
business undertaking as well as other businesses, amount of the investment in A Ltd., which is
whereas post demerger, it was represented only by derecognised by X Ltd.
its interest in businesses retained by A Ltd. Although a. Cost represented by fair value: Where the additional
X Ltd. did not pay any explicit consideration for the shares in B Ltd. represent a new or different
shares allotted to it in B Ltd. as part of the demerger investment acquired in exchange for a part of
scheme, there is an implicit cost associated with investment in A Ltd., they would be measured
them to the extent of reduction of its interest in A Ltd. initially at their fair value, with consequent
Currently Ind AS does not deal specifically with this recognition of gain or loss on derecognition of part
kind of issue, i.e. how the amount to be derecognised of investment in A Ltd.
should be determined. Thus, reference should be
However, in order to determine whether these
made to Ind AS 8.
additional shares in B Ltd. represent a new or
different investment acquired in exchange for a part
Ind AS 8, inter alia, states that in the absence of of investment in A Ltd., analogy may be drawn to Ind
an Ind AS that specifically applies to a transaction, AS 16, Property, Plant and Equipment and Ind AS 38,
event or condition, judgement should be applied Intangible Assets, with regard to determination of
in developing and applying an accounting policy cost of property, plant and equipment or of intangible
that provides relevant and reliable information assets acquired in exchange for a non-monetary
to the users of the financial statements. While asset. As per this, the additional shares in B Ltd. may
applying such judgement, entities should represent a new or a different investment acquired,
consider the requirements in Ind AS dealing in exchange for a part of investment in A Ltd., if the
with similar and related issues and guidelines demerger results in a more than insignificant4 change
prescribed in the Conceptual Framework3. in:
• The risks and rewards associated with the business
undertaking transferred from A Ltd. to B Ltd. or
those associated with the other businesses carried
3. The Conceptual Framework for Financial Reporting sets out the on by B Ltd. or A Ltd., and/or
fundamental concepts for financial reporting that guide the International
• In the extent of X Ltd.’s exposure to the aforesaid
Accounting Standards Board (IASB) in developing IFRS Standards. It helps
to ensure that the Standards are conceptually consistent and that similar
risks and rewards.
transactions are treated the same way, so as to provide useful information
for investors, lenders and other creditors.
4. What is considered significant or insignificant is a matter of judgement.
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Ind AS Implementation Guide I 138
b. Cost representing the continuance of the pre- Accordingly, in the given facts of the case, it
existing investment: would be an appropriate view to take that the
In the present case, there is no ‘exchange’ of ‘cost’ of the additional shares is represented by
investments. X Ltd. continues to hold the same the amount derecognised by X Ltd. in respect of
number and proportion of equity shares in A Ltd. its investment in A Ltd. while accounting for the
after the demerger as it did before the demerger. demerger. (ITFG 20, Issue 4)
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139
Key principles
• Basic Earnings Per Share (EPS) is calculated by • An entity that reports a discontinued operation shall
dividing profit or loss attributable to holders of disclose the basic and diluted amounts per share for
ordinary equity of the parent (the numerator) by the discontinued operation either in the statement
the weighted average number of ordinary shares of profit and loss or in the notes.
outstanding (the denominator) during the period. • When an entity presents both CFS and SFS
• Where any item of income or expense which in accordance with Ind AS 110 and Ind AS 27
is otherwise required to be recognised in profit respectively, the disclosures required are to
or loss in accordance with Ind AS is debited or be presented both in the CFS and SFS. In CFS,
credited to securities premium account/other such disclosures shall be based on consolidated
reserves, the amount in respect thereof is required information and in SFS, such disclosures shall be
to be deducted from profit or loss from continuing based on information given in SFS. An entity is
operations for the purpose of calculating basic EPS. prohibited from presenting EPS in CFS based on the
• Diluted EPS is calculated by adjusting profit or loss information given in SFS and vice versa.
attributable to holders of the ordinary equity of the
parent, and the weighted average number of shares
outstanding, for the effects of all dilutive potential
ordinary shares.
• Potential ordinary shares shall be treated as dilutive
when, and only when, their conversion to ordinary
shares would decrease EPS or increase loss per
share from continuing operations.
• If the number of ordinary or potential ordinary
shares outstanding increases as a result of
a capitalisation, bonus issue or share split, or
decreases as a result of a reverse share split, the
calculation of basic and diluted EPS for all periods
presented shall be adjusted retrospectively.
• If these changes occur after the reporting period
but before the financial statements are approved for
issue, the per share calculations for those and any
prior period financial statements presented shall be
based on the new number of shares.
• Basic and diluted EPS for profit or loss from
continuing operations and profit or loss for the
period for each class of ordinary shares that has
a different right to share in profit for the period, is
required to be presented in statement of profit
and loss with equal prominence for all periods
presented.
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Ind AS Implementation Guide I 140
Guidance from ITFG clarifications entity refers to profit or loss of the consolidated
entity after adjusting profit attributable to Non-
Consideration of amounts debited to Foreign Controlling Interests (NCI). (ITFG 11, Issue 3)
Currency Monetary Item Translation Difference
Account (FCMITDA) for computation of basic EPS
A company may have availed the option given under
paragraph D13AA of Ind AS 101. This means, that it
continued to apply the accounting treatment permitted
by paragraph 46/46A of AS 11, The Effects of Changes
in Foreign Exchange Rates. Accordingly, the company
has accumulated such exchange gains/losses in the
reserve FCMITDA.
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141
As the expression ‘unavoidable costs of the sales overhead and head office expenditure
meeting the obligations under the contract’ is etc. should not be considered while creating a
not defined, it was clarified that the expression provision for onerous contract, since such costs
‘unavoidable costs’ means the costs that could do not relate directly to a contract.
not be avoided due to existence of contract. Additionally, the EAC clarified that in a contract to
These are the costs that directly relate to supply the product, the costs should include all
the contract for example, direct labour, direct costs till supply of the product including the cost
material, allocations of costs that relate directly to of supplying the product (since Ind AS 37 requires
contract activities, etc. an entity to provide for all the costs to fulfil the
Generally, the administrative overheads, finance obligations under the contract).
charges, research and development expenses,
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Ind AS Implementation Guide I 144
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145
Operating Segments
The core principle is the disclosure of information that enables users of an entity’s financial
statements to evaluate the nature and financial effects of the business activities in which it
engages and the economic environment in which it operates. The core principle is considered
when forming judgements about how and what information is disclosed.
Key principles
• Ind AS 108 applies to entities to which Ind AS apply assets, and about major customers, regardless of
as notified under the 2013 Act. It is primarily a whether that information is used by management in
disclosure standard. making operating decisions.
• Its core principle is that an entity is required to • An entity is also required to give descriptive
disclose information to enable users of its financial information about the way the operating segments
statements to evaluate the nature and the financial were determined, the products and services
effects of the business activities in which it engages provided by the segments, differences between
and the economic environment in which it operates. the measurements used in reporting segment
• If a financial report contains both the CFS of a parent information and those used in the entity’s financial
that is within the scope of this Ind AS as well as the statements and changes in the measurement of
parent’s SFS, segment information is required only segment amounts from period to period.
in the CFS.
• Operating segments are components of an entity Significant differences from IFRS1
about which separate financial information is
available that is evaluated regularly by the Chief IFRS 8, Operating Segments, requires that it
Operating Decision Maker (CODM) in deciding how is applied to the separate or individual financial
to allocate resources and in assessing performance. statements of
• Generally, financial information is required to be an entity as well as the CFS of a group with a
reported on the same basis as is used internally parent:
for evaluating operating segment performance and a. Whose debt or equity instruments are traded
deciding how to allocate resources to operating in public market (a domestic or foreign stock
segments. exchange or an over-the-counter market,
• It requires an entity to report a measure of operating including local and regional markets) or
segment profit or loss and of segment assets. It b. That files, or is in the process of filing its
also requires an entity to report a measure of financial statements or CFS with a securities
segment liabilities and particular income and commission or other regulatory organisation for
expense items if such measures are regularly the purpose of issuing any class of instruments
provided to the CODM. in a public market.
• It requires reconciliations of total reportable However, the applicability and exemptions to
segment revenues, total profit or loss, total assets, the Ind AS are governed under the 2013 Act and
liabilities and other amounts disclosed for reportable the Rules made thereunder. Consequently, Ind
segments to corresponding amounts in the entity’s AS 108 does not include the above applicability
financial statements. requirements as included in IFRS 8.
• It requires an entity to report information about
the revenues derived from its products or services
1. Indian Accounting Standards (Ind AS): An Overview (Revised 2019) issued
(or groups of similar products and services), about by ICAI.
the countries in which it earns revenues and holds
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Ind AS Implementation Guide I 146
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147
8 Guidance on whether an entity that earns no revenue can be classified as an operating segment
11 Guidance on reporting different operating segments for entities in the same industry
12 Guidance on reporting as operating segment where chief operating decision maker only reviews
revenue information
13 Guidance on whether an entity is required to provide separate disclosures for each of its
operating segments
14 Guidance on aggregation of segments
15 Guidance on the ‘economic characteristics’ that would need to be ‘similar’ for the purpose of
aggregating operating segments
16 Guidance on when products/services, production processes, customers, distribution methods
and regulatory environment are said to be of similar nature
17 Guidance on application of 10 per cent thresholds test based on profitability criteria when
certain segments report profits and certain segments report losses
18 Guidance on how an entity should perform the 10 per cent test when different operating
segments report different measures of segment profitability and segment assets
19 Guidance on aggregation criteria being different from the aggregation criteria
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Ind AS Implementation Guide I 148
25 Guidance on aggregation of an operating segment that does not meet quantitative threshold
individually with a reportable operating segment
26 Guidance on measurement of segment’s profit or loss to be reported when the CODM is
provided with more than one measure of segment’s profit or loss
27 Guidance on key terms such as ‘segment profit’, ‘segment loss’, ‘segment assets’ and
‘segment liabilities’ in the absence of any definition in Ind AS
28 Guidance on alignment of operating segments reported by subsidiary with that of parent entity
29 Guidance on formula to be used when inconsistent cost formula for inventory valuation,
financial reporting and reports to CODM for evaluating performance is used
30 Guidance on treatment of discontinued operation under Ind AS 108
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149
Applicability of Ind AS
The core principle is the disclosure of information that enables users of an entity’s financial
statements to evaluate the nature and financial effects of the business activities in which it
engages and the economic environment in which it operates. The core principle is considered
when forming judgements about how and what information is disclosed.
The ITFG has dealt with a number of issues regarding the financial year (i.e. by March 2018), would be
applicability based on Ind AS road map. Some of the covered within phase II of the corporate road map.
relevant principles opined by ITFG are as follows: Since the process of listing for the entity had begun
at the beginning of the financial year, it would be
Guidance from ITFG clarifications required to prepare Ind AS financial statements for
the financial year 2017-18.
Applicability in case of net worth or listing criteria b. Scenario 2: Where the entity was listed at the
Once a company met the threshold criteria for beginning of the year but was de-listed during the
applicability of Ind AS, it would then be required to year, the ITFG clarified that the entity would need
comply with the Ind AS road map irrespective of the to comply with Ind AS from the same year (i.e.
fact that at a later date its net worth fell below the prepare Ind AS financial statements for 2017-18).
applicability criteria. In a situation relating to a debt- The basis for above clarification was the entity
listed company, where the company met the net was listed at the beginning of the year (2017-18)
worth criterion on 31 March 2014 (i.e. met the net irrespective of the fact that it was delisted as at the
worth criteria for phase I of road map), but later its net year end.
worth fell below the specified threshold. According c. Scenario 3: If the process of listing began during
to ITFG, the net worth of the company should be the year (in May 2017) but the entity could be listed
calculated in accordance with the SFS of the company as at the end of the year i.e. March 2018. The
as on 31 March 2014 (i.e. when the road map for process of listing had begun during the year (in
phase I companies became applicable. (ITFG 6, Issue May 2017) and the entity was listed at the end of
1) the year. Therefore, the entity was still required to
comply with Ind AS from financial year 2017-18. In
addition, it was clarified, had the entity been listed
Ind AS road map would be applicable to a during the year, say in November 2017, it would
company when it meets the listing criteria. If be required to provide Ind AS financial statements
a company ceased to meet the listing criteria for the quarter ending 31 December 2017 and
immediately before the mandatory Ind AS consequently for the year ended 31 March 2018.
application date, then it would not be required to d. Scenario 4: If an entity began process of listing
comply with Ind AS even if it met the criteria on a during the year but was listed post March 2018,
prior date. (ITFG 3, Issue 8) then the entity would be required to comply with
Ind AS and present Ind AS financial statements for
the year ending 31 March 2018.
Certain scenarios regarding applicability of Ind AS to e. Scenario 5: An entity (whose debentures were
an entity with net worth less than INR250 crore as on listed in May 2017) was neither in the process of
31 March 2018 were considered by the ITFG. Those listing at the beginning nor at the end of the year,
scenarios are as follows: but its debentures were de-listed in January 2018.
a. Scenario 1: The entity which was in the process It was clarified that such an entity would not be
of listing, in the beginning of the year (say, on 1 required to prepare Ind AS financial statements.
April 2017) and was listed only towards the end of (ITFG 15, Issue 4)
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Ind AS Implementation Guide I 150
Ind AS applicability to entities in a group (Case unlisted entity with net worth less than INR250 crore.
no. 1) Additionally, C Ltd. is an unlisted entity which holds 25
A Ltd., a listed entity, was covered in phase II of Ind per cent in A Ltd (i.e. C Ltd. is an investor company of
AS road map (i.e. would be required to prepare Ind A Ltd. with a net worth less than INR250 crore). D Ltd.
AS financial statements for financial year 2017-18 is another fellow subsidiary of A Ltd. i.e. subsidiary of
and onwards) while its holding company B Ltd. is an the holding B Ltd.
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151
Ind AS applicability to entities in a group (Case mentioned below) would be required to follow Ind AS
no. 2) from the implementation dates prescribed in the road-
The Ind AS corporate road map applies to all the map i.e. 1 April 2016 or 1 April 2017 respectively:
companies which meet the specified criteria (as
01 02 03
In this context, ITFG considered a situation where a Employees Stock Option Plan (ESOP) reserve in
parent (ABC Ltd) and its unlisted subsidiary PQR Ltd. computation of net worth
(with net worth of INR50 crore) complied with Ind AS In order to compute net worth for assessing
beginning 1 April 2017 considering the requirements applicability of Ind AS, ESOP reserve is required to be
of the road map. During financial year 2018-19, ABC included within net worth. The ITFG considered the
Ltd. sold off substantially all of its investment in PQR Guidance Note on Accounting for Employee Share-
Ltd. to an unrelated unlisted company, XYZ Ltd. based Payments, which., inter alia, provided that an
The issue under consideration is after the sale of its enterprise should recognise as an expense (except
shareholding in PQR Ltd. by ABC Ltd., would PQR Ltd. where service received qualifies to be included as a
and XYZ Ltd. be required to apply Ind AS. part of the cost of an asset) the services received in
an equity-settled employee share-based payment plan
when it receives the services, with a corresponding
ITFG clarified that entity (PQR Ltd.) is required credit to an appropriate equity account, say, ‘Stock
to continue to follow Ind AS, considering the Options Outstanding Account’. This account is
requirements of Rule 9 of Ind AS rules which transitional in nature as it gets ultimately transferred
provides that once a company adopts Ind AS to another equity account such as share capital,
voluntarily or mandatorily would continue to securities premium account and/or general reserve as
prepare financial statements under the Ind AS for recommended in the subsequent paragraphs of this
all the subsequent years. Guidance Note.
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Ind AS Implementation Guide I 152
Hence, Ind AS road map is not applicable to a branch Accordingly, in the given scenario, on the assumption
of a company that is not incorporated in India. (ITFG that the entity ceased to carry on the activities as
12, Issue 6) NBFC from July 2016 onwards, it would be required
Applicability of Ind AS road map to NBFC to comply with the requirements of Ind AS from July
performing such a role but not yet registered with 2016 onwards. (ITFG 15, Issue 5)
the RBI Applicability of Ind AS to a Limited Liability
A company, awaiting its registration as NBFC with the Partnership (LLP)
RBI, may in the meanwhile, be performing the role A Ltd. was covered in phase I of the applicability of Ind
of NBFC. The definition of NBFC included in the Rule AS road map and accordingly prepared its first Ind AS
4(1) of the Companies (Indian Accounting Standards) financial statements for the year ended 31 March 2017.
(Amendments) Rules, 2016, laying down the road map Its wholly owned subsidiary, B Private (P) Ltd. also
for the applicability of Ind AS to NBFCs is very wide. It prepared its financial statements for the year ended
covers a company which is carrying on the activity of 31 March 2017 and thereafter for 31 March 2018 as
NBFC. per Ind AS even though it did not on its own meet the
net worth criterion for applicability of Ind AS road map.
Accordingly, a company which is carrying on
the activity of NBFC but not registered with RBI
would also be subject to the road map for the Company Ind AS
applicability of Ind AS applicable to any other (Ind AS compliant) Applicable?
NBFC.
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153
In accordance with the definition of defined Accounting treatment of plan assets, liability, etc.
contribution plan included in Ind AS 19, the liability In case an employee benefit scheme is treated as
of an enterprise is restricted only to the amount it defined benefit scheme, all the requirements relating
contributes to a separate fund for the benefit of its to recognition, measurement and disclosures of
employees and has no further obligation whatsoever the defined benefit expense, obligation and plan
beyond its contribution. assets, etc. as contained in Ind AS 19 should follow.
In case an entity has an independent exempt In accordance with Ind AS 19, the plan asset is to be
provident fund trust which manages its provident fund measured at fair value and defined benefit obligation
obligations towards its employees, such an entity is is to be measured at its present value using actuarial
required to mandatorily declare interest rate not below technique (projected unit credit method) and the
the rate announced by the Employee’s Provident difference between the two is to be recognised as
Fund Organisation (EPFO). Further, if the trust is net defined benefit liability (asset) in the balance
unable to meet such interest rate, then the employer sheet. However, gains and losses resulting from the
has to make good the shortfall. Thus, the employer remeasurement of net defined liability (asset) including
(company) guarantees a specified rate of return on the actuarial gains and losses are to be recognised in
contributions made and the liability of the enterprise Other Comprehensive Income (OCI).
is not restricted to the contribution it makes to the Disclosure to be made in financial statements
separate fund but also extends to any deficiency in An entity is required to make all the disclosures in
the rate of interest earned by the separate fund as accordance with Ind AS 19 related to the defined
compared to the rate declared by the EPFO. benefit plan in the financial statements.
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Ind AS Implementation Guide I 154
Provision for un-encashable portion of half pay embodying economic benefits and a provision should
leave as per Ind AS 192 be recognised where liability could be measured only
The nature of un-encashable leave is similar to that by using a substantial degree of estimation provided it
of the encashable leave. The reason is that even an meets the definition of liability.
un-encashable leave provides a right to an employee to But, Ind AS 19 does not provide detailed guidance
receive salaries and wages for the period for which he/ as to when and in what circumstances, employee
she avails leave as during that period he/she does not benefits should be considered to be expected to
render any services to the employer. be paid and accordingly whether there is any need
Accumulating Half Pay Leave (HPL) creates an to provide for the same in the financial statements.
obligation on the company because any unused Similarly, the Framework also does not give detailed
entitlement increases the employee’s entitlement to guidance on present obligation and when can it be
avail leave in future periods. Thus, a provision needs to considered to exist.
be recognised for all these benefits and recorded as In the above regard, however, Ind AS 37, Provisions,
part of the cost of service rendered during the period Contingent Liabilities and Contingent Assets provides
in which the service was rendered which resulted in detailed guidance on present obligation and the
the entitlement. circumstances in which liability/provision should be
In accordance with Ind AS 19, an obligation exists in recognised. A company should determine whether
respect of short-term accumulating compensated there exists a present obligation and therefore,
absences irrespective of whether these are vesting or whether a provision needs to be recognised or not in
non-vesting and is required to be recognised. Similarly, the specific facts and circumstances, considering all
a liability in respect of other long-term compensated the evidences/factors available at the reporting date.
absences is required to be provided as per Ind AS 19. If it is determined that a present obligation (legal or
Accordingly, it was clarified that irrespective of constructive) exists and other conditions as per Ind AS
whether accumulating HPL could be classified 37 are met, provision should be recognised. However,
as ‘short-term employee benefits’ or as ‘other where it is determined that ‘present obligation’ does
long-term employee benefits’, a liability on account not exist or due to any other reason, provision could
of compensated absences should be recognised. not be recognised, then, the company should also
Additionally, this liability should be reviewed at each consider whether there is any need for disclosure as a
reporting date to recognise the effect of any change in ‘contingent liability’ (unless the possibility of an
estimates in this regard. outflow of resources embodying economic benefits is
remote).
Provision for wage revision3
Amortisation of goodwill in respect of subsidiaries
In accordance with the Ind AS 19 when an employee and jointly controlled entities recognised as an
has rendered service during a period, the employee asset in Consolidated Financial Statements (CFS)4
benefits which are expected to be paid in exchange for
that service are required to be provided for as liability. On the date of transition, the carrying amount of
goodwill arising on consolidation of subsidiary or jointly
Further, as per the requirements of The Framework controlled entity as per Ind AS cannot be amortised
for the Preparation and Presentation of Financial under Ind ASs. In accordance with the principles of
Statements in accordance with Indian Accounting Ind AS, the carrying amount of goodwill or goodwill
Standards (the Framework), liability is a present acquired under business combination should be tested
obligation arising from past events, the settlement of for impairment periodically as per the guidance under
which is expected to result in an outflow of resources Ind AS 36.
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155
Other EMs
Refer to educational material on Ind AS 2 for following issues/topics:
Issue
Topic
number
1 Difference between ‘Net
Realisable Value (NRV)’ and ‘Fair Value (FV)’
2 Applicability of measurement criteria for certain type of inventories
3 Packing material and publicity material whether covered by the term ‘materials and supplies
awaiting use in the production process’
4 Exclusion of distribution costs from inventory
5 Recognition and disclosure of amount of reversal of any write-down of inventories
6 Free choice between First-In-First-Out (FIFO) and weighted average methods
7 Different cost formulae for inventories held at different geographical locations having similar
nature and uses to it
8 Costs to be considered while determining the NRV
9 Disclosure of the carrying amount of inventories pledged as security for liabilities - whether pledge
covers other kinds of charges/encumbrances
10 Accounting treatment of machinery spares- Similar to ITFG 2, Issue 4 included in chapter 4,
Tangible and intangible assets
11 Accounting treatment of excise duty1 for the purpose of valuation of inventories
1. This issue would apply to few companies e.g. petroleum products and tobacco.
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Ind AS Implementation Guide I 156
2 Adjustment of events occurring between end of the interim financial report and date of approval by
BOD
3 Date of approval for issue as per Ind AS 10 in the event of reopening of books of accounts by the
BOD
4 Events are adjusting or non-adjusting events and their treatment for
financial statements for the year 2016-17 when an entity receives a demand notice for an
additional amount from the Excise Department on 15 June 2017
5 Provisions to be made in the following cases for financial statements of the year 2016-17:
Scenario 1 For a debtor which suffered heavy losses due to an earthquake in February 2017 and
consequently became bankrupt in April 2017
Scenario 2
For a debtor which suffered heavy losses due to an earthquake after March 2017
6 Adjusting event- cost of project and profit to be adjusted in case of an adjusting event
7 Entity approached for arbitration in a case before the end of the reporting period. Whether this
event is an adjusting event and treatment of contingent asset (i.e. costs which were charged to
the statement of profit and loss as an expense for the year 2016-17)
8 Treatment of duty drawback credit where application not filed within time
9 Selling of goods at a discount if payments received within 15 days- whether discount would be
adjusted from the sales at the end of the reporting period
10 Exception to the principle that adjusting events are those that provide evidence of conditions that
existed at the end of the reporting period
11 Treatment of the fraud related to a prior financial year discovered after the end of the reporting
period but before the date of approval of financial statements
12 The value of investment found fraudulently inflated after the end of the reporting period but
before the approval of the financial statements
13 Disclosure requirements regarding significant non-adjusting events occurring after the end of the
reporting period
14 Disclosure of proposed dividend under Ind AS
15 Difference in the treatment of interim dividend declared and paid during the year vis-a-vis
proposed dividend
16 Treatment for dividends declared to redeemable preference shareholders after the reporting
period but before the financial statements are approved for issue
17 Preparation of financial statements on a going concern basis
18 Disclosure of a significant non-adjusting event-fire in a plant after the reporting date of 31 March
2017 and expected financial effect known
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157
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Ind AS Implementation Guide I 158
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159
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Ind AS Implementation Guide I 160
3 Accounting treatment for grants in the Chapter 10-Other topics (Accounting 126
nature of promoter’s contribution for government grants and disclosure
of government assistance)
ITFG Bulletin 10
1 Accounting for interest-free loan provided Chapter 9-First-time adoption of 97
by holding entity in its SFS Indian Accounting Standards
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161
4
Calculation of EPS by a subsidiary company
that is not wholly owned by its parent
Measurement of investment in
Chapter 10-Other topics-Earnings Per
Share
97
Benefits
subsidiaries, joint ventures and associates Accounting Standards
at the end of the first Ind AS financial
reporting period
5 Exemption of custom duty on capital goods Chapter 10-Other topics (Accounting 128
as government grant for government grants and disclosure
of government assistance )
6 Uniform accounting estimates vs. uniform Chapter 10-Other topics (Accounting 122
accounting policies policies, changes in accounting
estimates and errors)
Chapter 1-Consolidation 6
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Ind AS Implementation Guide I 162
ITFG Bulletin 13
1 Capitalisation of DDT paid on preference Chapter 10-Other topics (Borrowing 35
share dividend costs)
2 Financial guarantee contracts(disclosure of Chapter 3-Financial instruments 134
financial guarantee (without any fee) given
by a director)
3 Information about major customers where a Chapter 10-Other topics (Operating 146
company operates only in one segment Segments)
ITFG Bulletin 14
1 Capitalisation of processing charges to the Chapter 10-Other topics (Borrowing 130
cost of the qualifying asset costs)
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163
Benefits
Chapter 3-Financial instruments 35
3 Incentives receivable from the government Chapter 3-Financial instruments 27
considered as financial instruments
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Ind AS Implementation Guide I 164
ITFG Bulletin 18
1 Exemption under paragraph D13AA of Ind Chapter 9-First-time adoption of Indian 98
AS 101 vis-a-vis borrowing costs under Ind Accounting Standards
AS 23
Chapter 10-Other topics (Borrowing 131
costs)
2 Deferred taxes on undistributed profits Chapter 5-Income taxes 62
3 Low interest and interest free financial Chapter 3-Financial instruments 37
instruments
4 Retrospective restatement of business Chapter 2- Business combinations 19
combination under a court scheme
5 Applicability of Ind AS to LLP Chapter 10-Other topics (Applicability 152
of Indian Accounting Standards)
ITFG Bulletin 19
1 Business combination accounting in case of Chapter 9-First-time adoption of Indian 102
acquisitions by first-time adopter Accounting Standards
4 Application of capitalisation rate for assets Chapter 10-Other topics (Related party 131
acquired under business combination disclosures)
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165
6
Restatement of financial statements of
entities under common control
Application of Ind AS to entities in a group
Chapter 2- Business combinations
151
Benefits
of Indian Accounting Standards)
ITFG Bulletin 20
1 Disclosure of foreign exchange differences Chapter 8-The effects of changes in 89
separately from other fair value changes foreign exchange rates
2 Consolidation by an investment entity Chapter 1-Consolidation 5
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Ind AS Implementation Guide I 166
ITFG Bulletin 23
1 Measurement of current tax and DTA/DTL Chapter 5-Income taxes 65
to give effect to lower tax rates
Chapter 10-Other topics (Accounting 122
policies, changes in accounting
estimates and errors)
2 Accounting treatment of deferred tax Chapter 9-First-time adoption of Indian 104
adjustments recognised in equity on Accounting Standards
first-time adoption of Ind AS in accordance
with Ind AS 101, at the time of transition to Chapter 5-Income taxes 65
Ind AS 115 and Ind AS 116
Chapter 6-Revenue 70
Chapter 7-Leases 82
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167
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Ind AS Implementation Guide I 168
December-19 Deferred tax under Ind AS 12 on fair value Chapter 5-Income taxes 66
changes of investment u/s 112A of IT Act,
1961
January-20 Accounting treatment of expenditure Chapter 4-Tangible and 54
relating to employee benefits expenses, intangible assets
rent expenses, travelling expenses and
house-keeping expenses which are
compulsorily required to be incurred for
construction of the project
Vol 36 Accounting treatment and disclosure Chapter 10-Others 153
(June 2019) requirement for contribution to exempt
provident fund
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169
Notes
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Ind AS Implementation Guide I 170
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