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Guide3 min readPublished

CARO clause 3(i)(c): title deeds of immovable property

What CARO clause 3(i)(c) requires an auditor to check on title deeds of immovable property, how to build the schedule of exceptions, and how leasehold property is reported differently from owned property.

CARO clause 3(i)(c) requires the auditor to report, for all immovable property (other than properties where the company is the lessee and the lease agreements are duly executed in favour of the lessee) disclosed in the financial statements, whether the title deeds are held in the name of the company, and if not, to disclose specified particulars in a prescribed format; this means physically reconciling every immovable property line item on the fixed asset register to an actual title deed or conveyance document, not just to a purchase invoice or stamp duty receipt, and the exact format and threshold wording should be confirmed against the current order.

What counts as immovable property here

The clause covers land and buildings disclosed in the financial statements, whether classified as property, plant and equipment, investment property, or capital work-in-progress. Properties held on lease are reported only to the extent the lease agreement is not duly executed in favour of the company as lessee; a validly executed lease does not need a title deed because the company never held title in the first place.

Testing approach

  1. 01Extract every immovable property line itemPull land and buildings from the fixed asset register, investment property schedule and capital work-in-progress schedule, with original cost, acquisition date and location.
  2. 02Call for the actual title document for each propertyA registered sale deed, conveyance deed or allotment letter from a development authority, not a property tax receipt or an internal valuation report, which prove occupation but not title.
  3. 03Match the name on the deed to the company's legal nameCheck for name mismatches from predecessor entities, mergers, or amalgamations where the deed was never transferred into the surviving company's name, and for properties still in the name of a promoter or a group company.
  4. 04Confirm lease agreements are duly executed where leasehold is claimedAn unregistered or unsigned lease, or one that expired and was never renewed, moves the property out of the lease exclusion and into the reportable category.
  5. 05Build the exceptions schedule in the prescribed formatFor every property where title is not in the company's name, record description, gross carrying value, held in the name of, whether a promoter or a director or their relative or employee, period held, and reason for the title not being in the company's name.
Common reasons title is not in the company's name
SituationAudit implication
Property acquired via merger, deed never re-registeredReportable unless legal transfer completed before the balance sheet date
Property jointly held with a group company or promoterReportable with the co-holder identified; assess whether it is also a related-party matter
Agreement to sell executed but conveyance deed pendingReportable; an agreement to sell is not a title deed
Leasehold land with an expired lease deed awaiting renewalNo longer within the lease exclusion once the term has lapsed; treat as reportable
Common reasons title is not in the company's name

Do not accept a photocopy of a title deed obtained once, years ago, as sufficient evidence for the current year. Confirm the deed is still held by the company, has not been pledged or encumbered in a way that affects title, and has not been superseded by a court order or attachment during the year.

Regulatory requirement

The exact clause number, prescribed disclosure format and the lease exclusion wording are set out in the Companies (Auditor's Report) Order as currently in force. Confirm all of these against current source material before drafting the report.

This is practical guidance written for audit teams, not an authoritative statement of any standard or statute. Standards, forms and timelines change. Check the current text issued by the ICAI and the relevant authority before relying on anything here in an audit file.

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