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This NFRA Staff Series document is an educational and illustrative guidance note designed to promote audit quality and awareness of professional standards, focusing on the Risk of Material Misstatement (ROMM) assessment at the assertion level for revenue. Anchored primarily in SA 315 and SA 240, the memorandum explains how auditors should identify, assess, and respond to inherent risk, control risk, and fraud risk through a structured, iterative process. Using a comprehensive hypothetical case study of a pharmaceutical company, the document demonstrates detailed ROMM work papers for revenue from sale of products, including risk identification, assertion mapping, evaluation of internal controls (manual and automated), fraud considerations, and planned audit responses through control testing and substantive procedures. It highlights areas such as variable consideration, cut-off risks, management bias, and revenue estimates as significant or fraud-prone risks. The memorandum reinforces that ROMM assessment is judgment-driven rather than mechanical and underlines the importance of professional scepticism, documentation discipline, and alignment of audit procedures with assessed risks.

NFRA STAFF SERIES

RISK & RESPONSE MEMORANDUM: ROMM ASSESSMENT AT ASSERTION LEVEL FOR REVENUE – A SAMPLE DOCUMENT

Table of Contents
Sl.# Topic Page #
A.      Background- Professional Standard’s Requirements 2-5
B.       Risk of Material Misstatement (ROMM) for Revenue-Audit of Dhanvantri Limited by CA. Ram Lakhan & Associates 6-26
I Review and Signoff by Engagement Team 6
II Observations from Detailed Analysis of Financial Performance of Dhanvantri Limited 7-8
III ROMM Work Paper for Revenue (Sale of Products) of Dhanvantri Limited 9-21
IV Audit Firm’s Staff Guidance on ROMM 22-26

Objective of the document:

This document prepared by NFRA Staff is intended purely towards promotion of awareness of auditing and accounting standards and audit quality as part of NFRA’s education, training, seminar and advocacy initiatives, especially in support of the outreach activities being conducted, and in response to the feedback being received through such engagements.

Disclaimer:

1. NFRA and the subject matter experts do not accept any responsibility or liability for any loss caused to any person or any entity, howsoever arising from the use of or refraining from the use of the contents of this document. This document is not a policy/standard/recommendation/statement of Executive Body of NFRA, the Authority or the Government and is not issued as a substitute for any obligations of Auditors, Management, Those Charged with Governance (TCWG) including Audit Committees, as are provided in applicable law, rules, and regulations. This document shall not be used before any authority or judicial or quasi-judicial body examining the auditors’ duties and responsibilities under applicable professional standards.

2. The facts, circumstances, data and figures and the names used in this document are hypothetical; any similarity or resemblance to the name, character, data
and circumstances of any company or audit firm or entity is entirely coincidental.

Acknowledgements:

We acknowledge the contributions of subject matter experts CA. Nilanjan Paul, CA. Ajit Viswanath and CA. Mohan Lavi in developing this document.

A. Background- Professional Standards’ Requirements

Risk assessment lays the foundation for overall audit approach. SA 315, Identifying and Assessing the Risks of Material Misstatement Through Understanding the Entity and its Environment (SA 315) is intended to assist auditors in identifying and assessing the risks of material misstatement in a consistent and robust manner.

Brief introduction to the risk assessment process

SA 315 require auditors to identify and assess risks of material misstatement, whether due to fraud or error, through understanding of (a) the entity and its environment; (b) the applicable financial reporting framework; and (c) the entity’s system of internal controls. The execution of the iterative actions in the context of identifying and assessing risks of material misstatement are interdependent concepts, which are important to establishing a sound basis and foundation for an audit. The quality of auditor’s risk identification and assessment process, therefore, has a pervasive effect on all aspects of the audit.

The risk assessment framework under SA 315 highlights the dynamic and iterative nature of the process for identifying and assessing risks. The preliminary risk assessments, and planned responses to those assessments, may need to change when new information is obtained.

Risks of material misstatement

Audit risk is the risk that the auditor expresses an inappropriate audit opinion when the financial statements are materially misstated. Audit risk is a function of the risk of material misstatement and detection risk.

Risks of material misstatement may exist at two level viz. financial statement level (i.e., risks which are pervasive to the financial statements) and relevant assertion1-level for significant classes of transactions, account balances or disclosures. Initial identification and assessment of risks of material misstatement at the assertion level consists of following two components:

  • Inherent risk: The susceptibility of an assertion about a class of transaction, account balance or disclosure to a misstatement that could be material, either individually or when aggregated with other misstatements, before consideration of any related controls.
  • Control risk: SA 2002 defines Control risk as the risk that a misstatement that could occur in an assertion about a class of transaction, account balance or disclosure and that could be material, either individually or when aggregated with other misstatements, will not be prevented, or detected and corrected, on a timely basis by the entity’s internal control. Further, as per Para 26(c) to SA 315, the auditor shall relate the identified risks to what can go wrong at the assertion level, taking account of relevant controls that the auditor intends to test; As per para A130, the controls can be either directly or indirectly related to an assertion. The more indirect the relationship, the less effective that control may be in preventing, or detecting and correcting, misstatements in that assertion.

The auditor may assess the ROMM separately for Inherent risk and Control risk or on combined basis.

Detection risk is the risk that the procedures performed by the auditor to reduce audit risk to an acceptably low level will not detect a misstatement that exists and that could be material, either individually or when aggregated with other misstatements.

ROMM at Assertion Level

The table below depicts different types of assertions based on reading of paragraph 25(b) and A121 – A125 of SA 315.

Assertions Material Misstatement Categories
Transactions/Events during the audit period Account balances at the period end Presentation and Disclosure
Occurrence
Completeness
Accuracy
Cut-off
Classification
Existence
Rights and obligations
Valuation and allocation
Classification          and

understandability

Accuracy and valuation

According to para A124 of SA 315, the auditor may use the assertions described above or may express them differently, provided all aspects described above have been covered. The auditor may choose to combine the assertions about transactions and events with the assertions about account balances.

Risks that Require Special Audit Consideration

Significant risk (Para 27 & 28 of SA 315)

In exercising judgment as to which risks are significant risks, the auditor shall consider at least the following:

a. Whether the risk is a risk of fraud;

b. Whether the risk is related to recent significant economic, accounting, or other developments like changes in regulatory environment, etc., and, therefore, requires specific attention;

c. The complexity of transactions;

d. Whether the risk involves significant transactions with related parties;

e. The degree of subjectivity in the measurement of financial information related to the risk, especially those measurements involving a wide range of measurement uncertainty; and

f. Whether the risk involves significant transactions that are outside the normal course of business for the entity, or that otherwise appear to be unusual. (Ref: Para. A131-A135)

Risks for which Substantive Procedures alone do not provide Sufficient Appropriate Audit Evidence (Para 30 of SA 315)

Above type of risks may relate to the inaccurate or incomplete recording of routine and significant classes of transactions or account balances, the characteristics of which often permit highly automated processing with little or no manual intervention.

Where routine business transactions are subject to highly automated processing with little or no manual intervention, it may not be possible to perform only substantive procedures in relation to the risk. In such cases audit evidence may be available only in electronic form, and its sufficiency and appropriateness usually depend on the effectiveness of controls over its accuracy and completeness (Ref: Para. A140). This may also be the case in case of transactions of large volume say Revenue, Payroll, etc.

Fraud Risk

(Refer. Para 16 and 25 to 27 of SA 240, The Auditor’s Responsibilities Relating to Fraud in an Audit of Financial Statements)

Para 16 of SA 240 requires the auditor to perform certain procedures as part of his/her risk assessment procedures under SA 315 for use in identifying the risks of material misstatement due to fraud. Para 25 of SA 240 requires the auditor to identify and assess the ROMM due to fraud at financial statement level and at assertion level. Para 26 casts a responsibility on the auditor to presume fraud risk in case of Revenue, unless auditor is able to rebut that presumption. Further, para 47 of SA 240 mandates the auditor to document the reasons for the rebuttal.

Para 27 of SA 240 prescribes that the fraud risk, if any, has to be treated as significant risk.

The Auditor uses various approaches to assess the fraud risk including an approach based on concept of ‘Fraud Triangle’.

Revision of Risk Assessment

(Ref. Para. 31 & A142 of SA 315)

During the course of the audit based on the findings of audit procedures, the auditor’s assessment of ROMM at assertion level may change. In such event, the auditor shall revise the assessment and modify the further planned audit procedures.

B. Risk of Material Misstatement (ROMM) for Revenue – Audit of Dhanvantri Limited by Audit Firm CA. Ram Lakhan & Associates

(Notes: This sample ROMM Work Paper for an important financial statement line item (FSLI) i.e., Revenue has been developed for education and training purposes. This ROMM assessment is at assertions level only. It is designed for audit of Standalone Financial Statements (SFS) as well as Consolidated Financial Statements (CFS). In case an audit firm is engaged for an audit of SFS only, contents of this sample document need appropriate changes.)

1. Review and Signoff by Engagement Team

Name & Designation Signature Date
Prepared by CA. Bharat, Engagement Supervisor 5th November 20XX
Reviewed by CA. Laxman, Engagement Manager

CA. Sushrut, Information System Audit Expert

10th November 20XX
Approved by CA. Ram, Engagement Partner 15th November 20XX
Reviewed by CA. Charaka, Engagement Quality Control Reviewer 16th November 20XX

II. Observations from Detailed Analysis of Financial Performance of Dhanvantri Limited

This ROMM work paper is for a key source of revenue of Dhanvantri Limited i.e., sale of pharmaceutical products. Separate ROMM work papers will be prepared for other sources revenue of Dhanvantri Limited. Further this ROMM work paper is for audit of Standalone Financial Statements of Dhanvantri Limited. Our firm is also auditors of Consolidated Financial Statements of Dhanvantri Limited and separate ROMM work papers will be prepared for each material component, whose financial information is included in the Consolidated Financial Statements, in co-ordination with the component auditors of those material components. In case of non-material components, we will be applying other audit procedures such as analytical review etc., as considered appropriate under individual facts and circumstances.

Financial Reporting Framework Applicable

Dhanvantri Limited is a listed company, therefore, required to follow Indian Accounting Standards prescribed under Companies (Indian Accounting Standards) Rules 2015. Accordingly, the requirements of Ind AS 115, Revenue from Contracts with Customers are applicable for accounting for Revenue of Dhanvantri Limited. We have performed details review of the nature and type of revenue transactions of Dhanvantri Limited and note that Ind AS 115 application does not pose significant risk from accounting point of view except for Ind AS 115 prescriptions relating to variable consideration in para 50 -59. The variable consideration prescriptions affect the timing and amount of recognition of revenue due to various discount and promotional schemes of Dhanvantri Limited introduced from time to time. However, our discussion with Sales and Marketing Head revealed that the Dhanvantri Limited has not introduced any new incentive or promotional schemes during the year under audit.

Revenue profile of Dhanvantri Limited for the year under audit

(For information about Dhanvantri Limited’s Sales, Distribution and Marketing department organisational structure, sales policy, process and controls, refer documents attached to ROMM Work Paper)

₹ Crores

Particulars 31.03.20X(Y-2) (Previous Year 2) 31.03.20X(Y-1) (Previous Year 1) Current Year Ending 31.03.20XY
Actuals Actuals (9 Months) Forecast (12 Months)
A. Revenue from contracts with customers 205,000 204,000 158,000 225,000
Provision for sales return (500) (500) (200) (300)
Rebates, discounts, price reduction and others (3,500) (4,000) (2,800) (4,700)
Revenue as per contracted price, net of returns 201,000 199,500 155,000 220,000

Particulars 31.03.20X(Y-2) (Previous Year 2) 31.03.20X(Y-1) (Previous Year 1) Current Year Ending 31.03.20XY
Actuals Actuals (9 Months) Forecast (12 Months)
Disaggregated revenue by type 220,000
Sale of products 197,000 195,000 151,000 215,000
Sale of services 4,000 4,500 4,000 5,000
B. Other operating revenue 4,500 4,800 4,300 4,000

Our discussion with Sales and Marketing Head during the year revealed that the pharmaceutical industry across the globe witnessed a successful year, driven by demographic shifts and evolving patient needs. Back home in India, the pharmaceutical industry continues to see strong growth of 7-10%. Dhanvantri Limited impressive revenue growth (forecast) of 9.75% is line with the industry trend. The key drivers in India are growing population, demographic and lifestyle changes, and increased access to modern medicines. These factors are further aided by Government of India incentive schemes such as Ayushman Medical Insurance scheme.

Review of published information

We have reviewed in detail the following information and data of Dhanvantri Limited and do not find any information that may have material impact on our ROMM for Revenue from Sale of Products.

1. Annual Reports for the year audit and previous year.

2. Quarterly financial results submitted to stock exchange i.e., Bombay Stock Exchange (BSE).

3. Earnings call transcripts and press releases on the website of Dhanvantri Limited.

Our Engagement Team also had discussions with Sales, Distribution and Marketing Team of Dhanvantri Limited.

III ROMM Work Paper for Revenue (Sale of Products) of Dhanvantri Limited Assessment of Risk of Material Misstatement for Revenue- Risk and Response Summary

Objective  

This workpaper has been prepared to document the evaluation of

(a)  risk of material misstatement (ROMM/ RMM) for the identified account captions and disclosures including the relevant risk factors that were considered to assess the level of inherent risk,

(b) the assertions at which the risk exists

(c)  evaluation of whether a risk of fraud exists

(d) the process level controls identified to address the relevant risks and the planned control reliance approach

(e)  planned audit response with respect to the identified risks

Overall summary of ROMM for Revenue from Sale of Products

ROMMs Inherent Risk Control Risk Fraud Risk Overall ROMM
Sl.# ROMM Description Manual Controls IT Environment
ROMM 1 Revenue is recognised for arrangements that do not meet the definition of a contract under the standard or do not exist. (Ind AS 115) Medium (M) Low (L) NA No Low (L)
ROMM 2 Revenue is not accurately recorded because the transaction price is not appropriately determined as per Ind AS 115 Significant (S) NA Low (L) Yes Significant (S)
ROMM 3 For performance obligations satisfied at a point in time, an inaccurate amount is recorded for revenue. Medium (M) NA NA No Low (L)
ROMM 4 For performance obligations satisfied at a point in time, revenue is not recognised in the correct accounting period. Significant (S) High (H) Low (L) Yes Significant (S)

Based on above analysis, overall ROMM for Dhanvantri Limited Revenue from sale of products is ‘Significant’.

(Note: However, this assessment is not a mathematical exercise. Engagement Teams have to exercise professional judgment and apply professional skepticism to estimate these risk bucket levels)

These ROMM levels will be considered in determining the nature and extent of testing e.g., sample sizes for both test of controls and substantive tests.

Summary of Inherent Risk Assessment (Also refer Audit Strategy Document for Preliminary Findings

Sl. No.
Accounts/
Disclosures
Amt
Assertions
Inherent risk Level
Fraud Risk?
Control
risks &
testing
Substantive Procedures
Estimation involved?
(₹)
Complete- ness
Existence/ Occurrence
Accuracy/ Valuation
Cut off
Rights & Obligat ions
Factors /Note 1
Level
Note 2
ROMM 1
Sale of products
xxx
Y
Y
Note
1.1
M
No
Refer Section
1a
Manual Control
Yes
(Refer Section 2)
No
Provision for sales return
xxx
Estimate    on
revenue
chargeback
xxx
ROMM 2
Sale of products
xxx
Y
Y
Note 1.2
S
Yes Note 2.1
Refer Section 1b Auto-mated Control
Yes (Refer Section 2)
Yes (Refer Section 3)
Provision for sales return
xxx
Estimate    on
revenue
chargeback
xxx
ROMM 3
Sale of products
xxx
Y
Y
Note 1.3
M
No
Yes
Yes (Refer Section 2)
No
ROMM 4
Sale of products
Dossier revenue
(in cases where it does not qualify as
a      separate
performance obligation)
xxx
Y
Y
Y
Note
1.4
S
Yes
Note
2.2
Yes
Yes
No
Other ROMM, if any
Other accounts
xxx
Other factors specific to engagement

Note 1 – Factors considered assessing level of Inherent Risk

Note 1.1 ROMM 1

The company has large volume of transactions across various geographies. However, given the non-complex nature of contract arrangement, the inherent risk

is evaluated as Medium.

Note 1.2 ROMM 2

The Company has agreements with its customers whereby the Company provides adjustments/ discounts/ rebates to the transaction price based on various criteria (including sale volumes, channel wise sales etc). This involves assumptions and estimations which has a possibility of management bias and risk of fraud. Accordingly, the risk has been determined as Significant.

Note 1.3 ROMM 3

Given the volume of activity and the size of account balance, there is susceptibility to error and hence the risk evaluated is Medium.

Note 1.4 ROMM 4

There are pressures on the management to meet revenue targets; the management performs cut-off adjustments at the period end to prevent incorrect revenue recognition, and historically there is an increase in sales near the period end, and this may provide opportunities for the management to manipulate the revenue recognition. Therefore, a risk of fraud has been identified with respect to this ROMM. Accordingly, significant risk is identified w.r.t early recognition of revenue

Note 2 Factors considered in assessing Fraud Risk

Note 2.1 ROMM 1

This involves assumptions and estimations which includes a possibility of management bias; hence a risk of fraud has been identified.

Note 2.2 ROMM 4

There is a significant pressure on the senior management of the company to meet its revenue targets and accordingly, Engagement Team (ET) has evaluated overstatement of revenue near the period end as a fraud risk.

1a. Identified Manual Controls (other than controls relating to estimates)

(Refer Separate Work Papers on Flow Charts and Walkthroughs for identification of these manual controls)

Sr.no.
What could go
wrong
(WCGW)?
(Refer Note 2)
Control
Description
(Manual)
How is the control
performed and
documented
(control
attributes)?
Level of
Precision of
the control
Frequency of Control
Risk
associated
with
control
Planned
Sample size
Control reliance /
Control risk
ROMM 1
The revenue is not recorded based on
the    quantity
despatched
The
warehouse
manager
physically
counts the
goods at the
time      of
loading    /
despatch and agrees it with
the invoice
before approving the dispatch document
1.                          Physical
counting        by
Warehouse
manager        and
3.       Approval      by
warehouse manager
As this is a transaction level
control, and
there     is
consistency of performance
of control,
hence  the
level    of
precision
would  be
higher
Recurring
Low
To be decided
based    on
Statistical Sample Tables (Refer AICPA Sampling Guide 2019)
Yes       –             Control
reliance planned / Low control risk

Sr.no.
What could go
wrong
(WCGW)?
(Refer Note 2)
Control
Description
(Manual)
How is the control
performed and
documented
(control
attributes)?
Level of
Precision of
the control
Frequency of Control
Risk
associated
with
control
Planned
Sample size
Control reliance /
Control risk
ROMM 4
Since           the accounting     of revenue occurs at the time of raising of          invoice (through       the system)        the revenue may be recognised before the delivery of the goods    to the
customer (in the incorrect period).
Sales cut off working (containing the     actual
delivery date) is   prepared
by marketing team    and
reviewed by AGM Finance. Based on this sales cut-off
working period    end
adjustment entries    are
passed based by the
finance manager and approved by AGM Finance.
1.    AGM Finance reviews the cut off working     by
agreeing it to the delivery  details received    from logistics     provider
2. AGM Finance agrees the cut-off working with the period  end            entry
and approves the same
Since   the
control operates at a transaction level;   the precision             is evaluated to be high
Monthly
High
3
Yes       –             Control
reliance planned / Low control risk

1b. Identified Automated Controls (other than controls relating to estimates)

(Refer separate work papers of IS Audit Team for evaluation and assessment of Information Technology General Controls (ITGCs) and Application Controls)

S. No.
What could go
wrong
(WCGW)?
Control Description
(Automated)
Relevant IT
layers
(Application
/Database
/Network and
operating
system)
Automated
control category
(Access control /
Configuration
control /
Interface control
/ Other)
How is the
control
performed
and
documented
(control
attributes)?
Level of
Precision
of the
control
Risk
associated
with
control
Control
reliance /
Control risk
ROMM 1
Unauthorised creation /
amendments could be made to sales orders
Access right to create and update sales order is  restricted to
authorised personnel.
Application layer (SAP)
Access control
Access          right restriction
Automated control, High precision
Low
Yes – Control reliance
planned    /
Low control risk
Incomplete, inaccurate  and
unauthorised Customer Master creation
& updation
Access for customer master   creation       &
updation is restricted to authorised personnel.
Application layer (SAP)
Access          right restriction
Automated control, High precision
Low
Yes – Control reliance planned    /
Low control risk
Invoice could be raised without a sales order
The system is configured to permit invoice creation only against a valid sales order.
Application layer (SAP)
Configuration
Automated control, High precision
Low
Yes – Control reliance planned    /
Low control risk
Accounting entries         for
invoices may not be         passed
appropriately
The         system                       is configured to pass automated   entries in the  designated                  GL
codes for recognition of revenue
Application layer (SAP)
Configuration
Automated control, High precision
Low
Yes – Control reliance
planned    /
Low control risk

S. No.
What could go
wrong
(WCGW)?
Control Description
(Automated)
Relevant IT
layers
(Application
/Database
/Network and
operating
system)
Automated
control category
(Access control /
Configuration
control /
Interface control
/ Other)
How is the
control
performed
and
documented
(control
attributes)?
Level of
Precision
of the
control
Risk
associated
with
control
Control
reliance /
Control risk
Unauthorised or
Access for price master
Application
Access control
Access right
Automated
Low
Yes – Control
ROMM 2 and
unapproved updation to price master, Inaccurate recording of sale proceeds.
creation & updation is restricted to authorised personnel
layer (SAP)
restriction
control, High precision
reliance planned    /
Low control risk
The invoice
Invoice details relating
Application
Configuration
Automated
Low
Yes – Control
ROMM 3
price in the invoice may be incorrectly modified / edited
to item code and price are    automatically
copied from the price master and cannot be edited by the user
layer (SAP)
control, High precision
reliance
planned    /
Low control risk

2. Substantive Procedures (Summary of the approach for substantive procedures performed including nature, timing and extent)

S. No.
Substantive
procedure
reference
no.
Description of
the procedure
performed
Test of details or substantive analytical procedure
Nature of
procedure
(Inquiry /
Observation /
Inspection/
Reperformance)
Timing of
the
procedure
(Interim /
Final)
Extent of planned procedur e & Sampling approach
If Interim, what are the roll forward
procedures
?
Expert/
Specialist
involved?
(If any,
Refer
Section 4
If any Report is
used in substantive
test, describe how
completeness &
accuracy of
information tested
 
 
 
 
 
 
 
 
& 5)
 
 
SP1
Obtain transaction level confirmation
for revenue
relating to the top two parties [comprising of
30% of
population]
Test of
details
Inspection (confirmation)
Final
Specific item testing
NA
NA
The sales reports
have been
reconciled with GL
for completeness.
Samples are selected from Sales register
and agreed to
underlying
documentation for
accuracy
ROMM 1
and
ROMM 3
SP2
For balance population, test the invoices by agreeing the underlying documents such as
shipping note/
delivery note,
customer acknowledgem
ent, customer
Test of details
Inspection
Final
Statistical
sampling
approach
NA
NA
Refer above
 
 
PO/ contract
 
 
 
 
 

S. No.
Substantive
procedure
reference
no.
Description of
the procedure
performed
Test of details or substantive analytical procedure
Nature of
procedure
(Inquiry
!
Observation !
Inspection!
Reperformance)
Timing of
the
procedure
(Interim
!
Final)
Extent of planned procedur e & Sampling approach
If Interim, what are the roll forward
procedures
?
Expert!
Specialist
involved?
(If any,
Refer
Section 4
If any Report is
used in substantive
test, describe how
completeness &
accuracy of
information tested
& 5)
ROMM 4
SP 3
For invoices
raised close to the period end, examine underlying documentation
such         as
shipping note/
delivery note,
customer acknowledgem
ent, customer
contract     to
determine
whether   the
invoices were
recognised in
the right period
Test of
details
Inspection
Final
Statistical sampling
NA
NA
Refer above
SP 4
For sales returns recorded post
year-end date, evaluate whether    it
impacts revenue recognised during the year
Test of details
Inspection
Final
Statistical sampling
NA
NA
Agree the              sales register to the trial balance as of April 202X

S. No.
Substantive
procedure
reference
no.
Description of
the procedure
performed
Test of details or substantive analytical procedure
Nature of
procedure
(Inquiry
!
Observation !
Inspection!
Reperformance)
Timing of
the
procedure
(Interim
!
Final)
Extent of planned procedur e & Sampling approach
If Interim, what are the roll forward procedures
?
Expert!
Specialist
involved?
(If any,
Refer
Section 4
& 5)
If any Report is
used in substantive
test, describe how
completeness & accuracy of
information tested
SP 5
For invoices
raised subsequent to the period end, examine underlying documentation such as shipping note/ delivery           note,
customer acknowledgem ent, customer contract to determine whether dispatch had
actually occurred after the period end, and there were no  invoices
pending to be recorded in the current  year
under audit
Test     of
details
Inspection
Final
Statistical sampling
NA
NA
Refer above

3. Estimates (Summary of the approach for procedures performed in response to estimate identified

ID
Estimate
Description
Underlying
Linked
Accounts
Estimate elements
Describe the approach to
test the Estimate
How is the
control
performed
and
documented
(control
attributes)?
Level of
Precision of
the control
Frequency of Control
1
Value of rights to return / Sales return provision     – the
dealers have the right to return the goods (pharma     products)
sold by the Company in case the inventory
expires.       This provision for                sales
returns is estimated
on   the    basis  of
historical experience, market conditions and        specific contractual terms.
Provision            for
sales return
Provision for sales returns are estimated  on  the  basis of
historical experience, market conditions        and specific contractual                        terms.  The
following elements make up the estimate –
Data – Revenue amount, and actual sales return for prior years.
Assumption      –                        Sales                        return percentage  (assumption     is
based on market conditions, historical     trends etc,
Method       –                   Sales  return
percentage is applied to the actual sales for the year to determine the amount of sales return provision
Control              testing To test the control framework – “Review of sales return provision     working                   on a periodic   frequency                (e.g.,
monthly basis) approved by VP-Finance
Substantive        testing
4. Perform    retrospective analysis with  respect to provision  for sales return
recognised in the previous years
5. Evaluate the method,
assumption & data used in the estimation process – i.e., for assumption consider the past returns    history,               agree the amount   of actual returns, actual   revenue      to the
company’s ledgers.
Approval by VP-Finance
As there is consistency of performance of control, hence the level of precision would   be
higher
Quarterly

ID
Estimate
Description
Underlying
Linked
Accounts
Estimate elements
Describe the approach to
test the Estimate
How is the
control
performed
and
documented
(control
attributes)?
Level of
Precision of
the control
Frequency of Control
2
Provision for chargeback
Estimate on revenue
chargeback
(including
discounts,
rebates, etc)
a) Method – The Company creates provision for chargebacks based on the inventory lying with the
distributors multiplied with the
expected Weighted average
charge back (WAC) rate.
b) Data – Closing inventory
with customers
c) Assumption – Weighted
average charge back rate
Control testing
To test the control framework – “Review of revenue charge back working on a periodic frequency (e.g., monthly basis) approved by VP-
Finance
Substantive testing
1. Perform retrospective analysis with respect to provision for sales return
recognised in the previous years.
1. Data & assumption – from the detailed listing of revenue charge back provision as of the YE date, for a selected
sample agree the closing
inventory with the report
received from the respective customer and evaluate the WAC rate by considering the
historical trends, inventory
pattern, etc.
Approval by VP-Finance
As there is consistency of performance of control, hence the level  ofprecision would be
higher.
Quarterly

4. Management’s Expert (The management Experts involved for getting assistance by management)

ID Name               of Management Experts Area involved/ Process affected Has the     auditor        also documented   procedures performed  to                   assess                   the
competency, capability and
objectivity      of specialists/ experts  engaged              by the management.
Type          of Specialist Procedures performed      by
Management Expert
Procedures performed by Auditor
Not applicable. Although accounting for revenue from sale of products of Dhanvantri Limited involves some estimations due to sales incentives, volume discounts and Sales Returns etc., Management Experts are not required/engaged in these estimation processes as these processes are not complex.

5. Auditors Expert ! Specialists (Other than IT Team)

The auditor involved the following Specialists! Experts to provide assistance for the purpose of audit as agreed in the planning meeting with the auditor:

ID Name               of Management Experts Area involved/ Process affected Has the    auditor        also documented    procedures performed  to     assess             the
competency, capability and
objectivity      of  specialists/experts  engaged              by        the
management.
Type          of Specialist Procedures performed by Auditor’s Expert
Not applicable. Although accounting for revenue from sale of products of Dhanvantri Limited involves some estimations due to sales incentives, volume discounts and Sales Returns etc., Audit Experts are not required/engaged in these estimation processes as these processes are not complex.

IV. Audit Firm’s Staff Guidance on ROMM

1. Risk Assessment Matrix

Our firm uses 3 x 3 Risk Assessment Matrix and performs ROMM at assertion level separately for Inherent Risk and Control Risk as depicted below.

Likelihood (Probability)

 

 

Severity (Magnitude)
Low Medium High
High Medium High High
Medium Low Medium High
Low Low Low Medium

Further, a combined ROMM is arrived using the following approach, subject to engagement team’s professional judgment, which would form the basis, along with assurance provided by analytical procedures, in deciding the nature and extent (Sample Size) of Test of Details (a type of substantive test).

Inherent Risk Control Risk Risk of Material Misstatement
High High High
High Medium High
High Low Medium
Medium High High
Medium Medium Medium
Medium Low Low
Low High Medium
Low Medium Low
Low Low Low

Note: The above exercise is not a mathematical exercise but needs the application of professional judgment and professional skepticism by the Engagement Team.

Additionally, the audit firm evaluates the classification of ROMM in Revenue as ‘Significant Risk’ or ‘Fraud Risk’ based on the criteria given in SA 315 or SA 240. Refer specific paragraphs below on these two critical audit areas.

Our firm’s methodology generally requires following confidence levels (quantitative terms) against each of the above risk bucket levels and those confidence levels will be used in determining nature & extent of testing (sample size determination using statistical audit sampling tables)

Risk Bucket Level Significant High Medium Low
Confidence Level 90-95% 80-90% 70% 30-50%

2. Evaluation of entity’s Internal Control System including Information Technology (IT) System

Entity’ internal control systems are significant components in achieving the management assertions regarding transactions and account balances that form part of the financial statements. Evaluation of internal control systems including IT platforms is an important part of our firm’s audit process. This aspect assumes added criticality in the audit assignments where we are required to express opinion on the design and operating effectiveness of company’s internal financial controls with reference to financial statements u/s 143(3)(i) of CA 2013.

Our firm’s audit methodology in this area is guided by prescriptions in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting3. A few important aspects to note are given below.

As per para 14.5 Guidance Note on Audit of Internal Financial Controls Over Financial Reporting “The auditor’s overall assessment of control risk for a particular assertion involves combining judgements about the prescribed controls, the deviations from prescribed controls, and the degree of assurance provided by the sample and other tests of controls”. Further, if the controls are expected to be operating effectively, then control risk is considered to be Low.

Risks associated with control

As per Para 113 to Guidance Note on Audit of Internal Financial Controls Over Financial Reporting – Factors that affect the risk associated with a control include:

♦ The nature and materiality of misstatements that the control is intended to prevent or detect;

♦  The inherent risk associated with the related account(s) and assertion(s);

♦ Whether there have been changes in the volume or nature of transactions that might adversely affect control design or operating effectiveness;

♦  Whether the account has a history of errors;

♦ The effectiveness of entity-level controls, especially controls that monitor other controls;

♦  The nature of the control and the frequency with which it operates;

♦  The competence of the personnel who perform the control or monitor its performance and whether there have been changes in key personnel who perform the control or monitor its performance; (Refer IG 6)

♦ The degree to which the control relies on the effectiveness of other controls (e.g., the control environment or information technology general controls);

(Refer IG 7 and IG 8)

♦ Whether the control relies on performance by an individual or is automated (i.e., an automated control would generally be expected to be lower risk if relevant information technology general controls are effective)

Level of Precision or Control Risk

As per para 19.10 Guidance Note on Audit of Internal Financial Controls Over Financial Reporting gives factors that auditors might consider when judging level of precision of control like consistency of performance, predictability of expectations, level of aggregation, purpose of control etc.

Overview of our firm’s overall approach for evaluation of internal control systems is given below.

3. Fraud risk assessment

Our firm uses an approach that is based on concept of ‘Fraud Triangle’ depicted below.

Our firm uses an approach

based on concept of ‘Fraud Triangle4. Audit Sampling approaches

Our firm generally uses the statistical sampling tables for selection of sample sizes prescribed in the globally used technical material issued by the AICPA . The reason being it is more aligned with the risk-based audit approach required under SAs and Audit Quality Control Standards and also it gives sample sizes for substantive tests and not just test of controls. In some cases of less complex audits, our firm uses the sample sizes given in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting referred earlier.

Notes:

1 Representations by management, explicit or otherwise, that are embodied in the financial statements, as used by the auditor to consider the different types of potential misstatements that may occur. SA 315.A123 further describes about assertions used by the auditor to consider the different types of potential misstatements.

2 SA 200, Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance with Standards on Auditing

3 Issued by the Institute of Chartered Accountants of India for the purpose of issuing audit report of adequacy and operating effectiveness of company’s internal financial controls with reference to financial statements u/s 143(3)(i) of CA 2013

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