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Rule 86B Decoded: 6 Exceptions When 99% ITC Restriction Does Not Apply

Summary: A fixed asset register may accurately record an asset’s cost, capitalisation and depreciation while failing to show where the asset is currently located. Routine transfers of machinery, laptops, furniture and other property, plant and equipment often occur without corresponding updates to asset records, creating avoidable discrepancies during physical verification. This is particularly relevant under Clause 3(i)(a)(A) of CARO 2020, which requires auditors to report whether proper records containing full particulars, including quantitative details and situation of property, plant and equipment, are maintained. Clause 3(i)(b) additionally addresses physical verification and material discrepancies. A practical asset movement register bridges the gap by recording transfers as they occur, identifying the releasing and receiving custodians and ensuring that the fixed asset register is updated promptly. Used consistently, it strengthens accountability and turns year-end verification from an investigation into a more straightforward confirmation exercise.

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Fixed Asset Movement Register and Asset Location Tracking

Ask any finance team what a machine cost, when it was capitalised, or how much depreciation has been charged on it, and you’ll get an answer in minutes. Ask where that machine is today, and the room often goes quiet.

That gap doesn’t show up in the books. It shows up at year-end physical verification, when the register says an asset should be in one place and the team finds an empty space.

Assets move, and nobody writes it down

Buying an asset leaves a clear paper trail: purchase order, invoice, goods receipt, capitalisation entry. Selling or scrapping it leaves one too, because it hits the accounts.

What happens in between is where things slip. A machine gets shifted when a production line is rearranged. A laptop goes with an employee who transfers to another branch. Chairs and tables get moved around during a renovation. These are everyday events, and in most companies none of them gets recorded anywhere.

So you end up with a fixed asset register that is right about cost and depreciation but wrong about location. When verification is done against it, many of the differences aren’t accounting errors at all. They’re location errors. But each one still has to be tracked down, explained and cleared before the audit can close.

Why “situation” matters under CARO 2020

Clause 3(i)(a)(A) of the Companies (Auditor’s Report) Order, 2020 requires the auditor to report whether the company maintains proper records showing full particulars, including quantitative details and situation, of property, plant and equipment.

“Situation” is the word to focus on. It means where the asset is now, not where it was installed five years ago. The moment an asset moves, a register that still shows its old location stops telling the truth about its situation.

Clause 3(i)(b) goes a step further. It requires reporting on whether management has physically verified property, plant and equipment at reasonable intervals, and whether any material discrepancies were properly dealt with in the books.

Put the two together and the logic is simple. Verification is the test. The register is what you test against. If the register doesn’t keep up with movements, verification turns into a treasure hunt.

For the auditor, the existence of property, plant and equipment is usually tested by physical inspection, with evidence gathered under SA 500 and procedures designed under SA 330. A movement register doesn’t replace that inspection. It just makes the results make sense, because the list being checked reflects where assets actually are.

What a good movement entry should capture

It doesn’t matter much whether you keep the register in a spreadsheet, an ERP module or an app. What matters is that every entry records:

  • the asset tag number and its code in the fixed asset register;
  • where it moved from and where it moved to, described the same way the register describes locations;
  • the planned date of the move and why it’s happening;
  • who released it and who received it;
  • who approved it, where the value calls for approval;
  • when it’s expected back, if the move is temporary, such as a repair;
  • the date the fixed asset register was updated.

The one field that most often stays blank is “received by”. It’s also the most important, because that signature is what moves responsibility for the asset to the new custodian.

Keeping the process alive in practice

Movement registers usually die for ordinary reasons. The form is too long. It gets filled in after the asset has already moved. Or nobody is responsible for approving it, so it quietly gets skipped.

A few simple habits make a real difference:

  • Fill in the entry before the asset moves, not after.
  • Set a value limit, so small routine moves don’t need a senior sign-off but expensive ones always do.
  • Use the same location names on the form as in the fixed asset register.
  • Once a month, match that month’s movement entries against the location changes made in the register.
  • Every quarter, check on assets that went out temporarily. Equipment sent for repair has a habit of never quite coming back on paper.

What changes at year-end

When movements are recorded as they happen, year-end verification becomes a confirmation exercise rather than an investigation. The differences that remain are real ones, and they’re easy to sort: not found, found without a tag, found somewhere else, or scrapped but still sitting in the books.

When movements aren’t recorded, the same exercise throws up a long list of items to chase before anyone can even say whether an accounting entry is needed. The real cost isn’t the verification. It’s piecing together what happened over the year.

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Author Info

Hitesh Aggarwal-Founder TagMyAssets
Qualification: CA in Practice
Company: TagmyAssets
Location: Gurgaon, Haryana
Articles Published: 25

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