Thursday, November 3, 2011

12 STRATEGIC PLAN 2020 ANNEXE 5 ANNEXE 6





Annexe 5 ­ 

Proposal for establishing a 
Chartered Institute of Public Accountants & Auditors of India (CIPAAI)
 


1.                 The Rationale for establishing CIPAAI
1.1 Finance, Accounts and Audit Management in India is currently being carried out in the Government by constituted Accounts and Audit Services and by Chartered Accountants, Cost and Works Accountants and MBAs in the Public Undertakings and private sector. These professionalsundertake financial,accountsand audit management functions at the middle and top levels. Whilethe certificationsby ICAI, ICWAI etc,areprofessionally recognised, the skills acquired by the Government Auditing and Accounting Services/ pro are without any professional recognition.

1.2 There also exists a multitude of finance,accounts andauditfunctionaries consisting of accounts clerks, accountants, auditors,assistants, treasury officials and others, who fill up the lower and the middle levels of the financial, accounting and auditing hierarchyin the Government. Though a few of these functionaries have a formal background in finance, accounts and audit,a majority of them do not possess professional qualifications. Even thosepossessing professional qualifications have acquired themonly at the entry point and do notgo in for upgradation/ continuing professional education in the course of their long career spanning 30 to 40 years. In the past, clearing the ‘SAS’ examination (currently known as the Section Officer Grade Examination) conducted by the Comptroller and Auditor General of India was considered as a suitable qualification for recruitment in other Public Sector Organisations. However, this practice has disappeared now.

1.3 The lack of professionalism amongst the lower and the middle level functionaries in this very important area of finance, accounts and auditing has led to deficiencies in the accounting processes and financial controls across organisations. There are huge arrears in the finalization ofaccounts of many institutions,both Governmental and Commercial. Even routine functions like reconciliation within offices are neglected. Internal Audit, which is required to flag accounting, control and other related issuesto the management, is most often nonexistent or ineffective. Finally the burden of this falls on the External Auditors, who havebeen pointing out numerous shortcomingsyear after year. The problem has acquired such acute dimensions that it has resulted in numerous court cases and indictments from the judiciary. The shortcoming has also been recognised by the multilateral agencies like the World Bank, Asian Development Bank etc.



1.4 One of the reasons for uneven and deficient accounting and auditing is the huge shortage of properly trained and skilled accounting/auditing personnel at the lower and middle levels. Without any professional qualification (apart from their experience), the lower/middle level accounts/audit functionariesdo not havea sophisticated understanding of the principles of accounting or the implementation of it. In the absence of any growth prospects linked to qualifications, they arenot




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adequatelymotivated to upgrade themselves in line with best practices. There is, therefore, a kind of vicious cycle that operates, leading to a lower level of efficiency and effectiveness in the finance, accountingandauditing processes in State Governments, State/Central Government undertakings, Cooperatives, Autonomous Organizations, Urban & Rural Local Bodies,Universities, Public utilities etc.

1.5 With the advent of globalisation, policy makers, state/central governments and end users, in India feel the need for upgrading and professionalising the skills of the finance, accounts and audit staff at the lower and middle levels. The Comptroller and Auditor General of India, World Bank and other Multilateral Funding Agencies have also flagged the need to upgrade the skills of the vast pool of finance,accounts and auditpersonnel in India. Further, the need for such upgradation is also validated by the fact that India is emerging globally as a leading service provider in business process outsourcing in the Financial Sector. In such a scenario it would be essential for a well‐established organisation like that of the Comptroller & Auditor General of India to take the lead and address the various issues detailed in the proposal.


1.6 There are a multitude of players in the Government and Non Government Sectors involved in managing and improving finance, accounts and audit administration in this country. Most of these institutions only address and tackle the higher level of financial policymaking, accounting and standards instead of day‐to‐day accounting problems and issues of professional upgradation at the grass roots level. While on one end we are looking at adoption of InternationalFinancial Reporting Standards(IFRS), computerisation of accounts, acceptance of Best Practices and even considering shifting to accrual accounting, the reality is thatgovernment/quasi government organisations do notoftenhave the accounting/auditing skills at the grass roots level even to maintain basis books of accounts on cash basis. This holds true for the private sector also where books of accounts in some of the small enterprises are still maintained in traditional single entry systems (bahi‐khata).

2.                 International Scenario
This problem has already been addressed in many countries by setting up professional bodies like the Government Finance Officers Association (GFOA),Association of Government Accountants (AGA)and Certified Government Auditing Professionals (CGAP) in the United States of America (USA), Chartered Institute of Public Finance and Accountancy (CIPFA) in the United Kingdom, Association of Accounting Technicians (AAT) in South Africa, Australia, Sri Lanka and the U.K. In Canada, certification in the form of “Certified General Accountant” (CGA) addresses this need. These Institutions/ certificationshave helped in bridging the gap of skill and knowledge requirements at the grass roots level. Even international organisations like United Nations are already addressing the issue of improvement in financial systems in their Millennium Development Goals. UNCTAD has also sought to bring out a set of Accounting Standards for small and medium enterprises.

3.                 Why the need for a separate Chartered Institute
3.1 It could be argued that the already existing Institution like the ICAI, ICWA etc. could address the issue of skill upgradation at the middle and lower levels of accounts professionals. However, the mandate and culture of these institutionsdo not easily facilitate them to undertake this task. The existing institutions have well‐established procedures, which cater to a predetermined select target




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group, which forms a miniscule elite. It would be difficult and disadvantageous for them to expand their processes to cater to a lower target group. Further, the existing Institutes have maintained their standards mainly due to the homogeneity of the background of their members. Hence it is essential that a separate national body establish a specialised institution aligning its objective of establishing a professional layer of lower/middle accountants/auditors with individual aspirations and qualifications. Since massive numbers across the countryareinvolved, a separate organisation with an identity is required.


3.2 In a federal setup, it is essential that a Chartered Institute of this kind be set up at the National level, since it has to be anational provider for upgrading and maintaining financial information with International credibility. Suchan Institute would strengthen grassroots level accounting and auditing all over the country in every sector and will have national acceptance and international validity. Further, this Institute would establish relationships and linkages with bodies within the country and abroad like CIPFA, CGA and AAT, which have similar objectives.

3.3 In India, there is no opportunity, apart from the entry‐level qualification (School Boards or undergraduate degree) for continuing upgradation of skill and knowledge for the finance, accounts and audit functionaries. Continuing education is required to be delivered in graded capsules over the average work span of 30 to 40 years. The proposed Institute would provide continuing professional education like an open universityto a multitude of persons all over the country through examinations, counseling and learning material. Hence,national and several sub‐national centreswould need to be set up. Therefore it would be impractical to link the proposed Institute with an already existing one. In other countries also,separate Institutes have been set up for this objective.

3.4 The proposed Institute would also provide low‐end advisory and consultancy services. The services could include setting up of internalaudit systems in institutions, guidance relating to accounting policies, procedures and practices in Municipalities and even in the private/Non Government Organisation (NGO) sector. This Institute could also undertake development of Management Information Reports from the Accounts of organizations so that the decision makers have relevant information. Creation of reliable data banks at the lower and middle levels could be another objective.

4.                 The Institute
The basic aim of the proposed Institution is to address the capacity building needs for lower and middle level finance, accounts and audit functionaries in India. The Institute could be known asthe Chartered

Institute of Public Accountants & Auditors of India (CIPAAI).

4.1  Vision Statement
Develop a largepool of highly trained middle and lower level finance and audit functionaries in India, which would in turn enable timely and relevant financial reporting for decision makers in line with best practices.









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4.2  Mission Statement

·      To raise the benchmark of knowledge and skills in finance, accounting and auditing for lower and middle level government/semi government/commercial and semi commercial functionaries in India.

·      To motivate the middle and lower level accounts functionaries by providing an opportunity to acquire a nationally recognised professional qualification supported by continuing professional certification.

·      To provide grass root level advisory consultancy & research services, accounting, internal audit, management information systems etc.

·      To disseminate professional information on finance, accounting and auditing to the members of the institute and other organisations in need of these services.

·      To serve as a centre of excellence for promoting generally accepted accounting and auditing standards at the institutional level including Government/Commercial Sector, Cooperatives, NGOs, Universities, Public Utilities, Autonomous Institutions, Urban and Rural Local Bodies.

4.3  Guiding values

·       To ensure complete transparency and fairness in the certification process.

·      To maintain impartiality and professionalism in providing technical support and guidance in respect of accounting systems, procedures and practices.

·      To advance accountability in organisations through individual excellence in accounts and audit.

·       To ensure integrity in performance of all the members of the Institute.

5.                 Directorates of CIPAAI

CIPAAI would function through 3 Directorates as listed below:

·      Directorate for Certification & Continuing Education (DCCE) will design, develop and conduct 5 levels of certification examinations, create new syllabus for training and prepare learning material for the examinations. The DCCE would also provide Distance education, counseling services and establish centres at the State and Regional levels. The first 3 levels of Certification Examinations would aim at addressing general areas of finance, accounting and auditing. The Section Officer Grade Examination being conducted by the CAG could be subsumed in the second and third levels. The fourth level would address the needs of specific sectors like power, municipalities etc. The fifth and highest level would address issues like accrual accounting, international best practices, ethics in profession, management information systems, certified information systems audit etc. The fifth level





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could also be the level for certifying the Indian Audit and Accounts Service Officers after their intensive training in the National Academy of Audit and Accounts, Shimla on joining the service. The Directorate would also be responsible for establishing programmes for Continuing Professional Education (CPE) for certified professionals, which would be mandatory for maintaining the validity of the certifications acquired (as is the case for other national/ international professional certifications); this would ensure that these professionals are kept up‐to date with the latest developments in the profession.

·      Directorate of Technical Guidance & International Relations (DTGIR) will provide technical guidance for accounting and auditing and give necessary expert opinion when referred to. DGTIR would maintain close interface with Government Accounting Standards Advisory Board (GASAB). DTGIR would also bring out a monthly newsletter to inform members about latest decisions/trends. This Directorate would study the interface with other organisations within the country and abroad in order to establish relationships and linkages with bodies in India and abroad, which have similar objectives.

·      Directorate of Membership Administration & Secretariat (DMAS) will inter‐alia administer and monitor membership and professional certification. The Secretariat would provide all the administrative support service to the CIPAAI.

6.                 Beneficiaries

The target group coming under the scope of CIPAAI would be in the range of10 to 20 lakhpersons from various sectors. The various levels of certification could be:

·       Levels 1, 2 and 3 certification

Ø  Lower & middle level governments/semi government/commercial & semi commercial staff in Central and State Government Organisations, Central and State Government Autonomous Bodies,Urban and Rural Local Bodies, Cooperatives and NGOs

Ø  Supervisory and lower cadre officials in the Indian Audit and Accounts Department and other accounts services of the Government of India (SOGE equivalent). While SOGE could be equivalent to level 3, the level 1 could be targeted at the accountant/auditor level examinations.

·       Levels 4 certification

Ø  Specific certification for sectors like Educational Institutions, Medical Institutions, Public Utilities – Power, Sewerage, Water etc.

·       Levels 5 certification (Highest Level Certification)







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Ø  Group A Officers of Indian Audit and Accounts Department and other accounts services of Government of India and State Governments.

7.                 Statutory Recognition for CIPAAI

The certification being issued by the CIPAAIwould require to be recognized by the government so that the certification being offered has value in the market. In order to operationalise CIPAAIas a separate chartered or national institute on the lines of ICAI or ICWAI,it would, therefore, be necessary to obtain parliamentary approval through passing of an Act. Thereafter, CIPAAI degree/certification could strive to have the same kindof recognition in the public auditing and accounting space that the CA certification enjoys in the commercial accountancy space.

8.                 Conclusion

The constitution of a Chartered Institute asoutlinedabove is likely to bea major step in overcoming deficiencies in the available knowledge and skill of the lower and middle level of finance, accounts and audit functionaries. It would serve as a body, which would provide professional certification for the lower and middle level finance, accounts and audit management, which the Institute of Chartered Accountants of India provides at the higher end. It would also provide professional certification to the Group A Audit and Accounts professionals entering into the Government of India and State Governments through Civil Service Examinations. This platform should work as a major provider, motivator and facilitator for upgrading finance,accounts and audit skills of those at the lower end of the hierarchy in the country and in adopting and implementing strategies evolved internationally. There would be quantum change in the quality offinance,accountsand auditin the country and thiscould also serve as a model for developing countries.
































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Annexe 6 – Suggested Approach to Integrated Financial­cum­Compliance Audit
 


1.                  Our regularity audit (i.e. financial and compliance audit) should result in an informed opinion on the overall public financial administration in the country‐ of the Government of India; separately for each state government; and together. The aimshould beto trace the rupee to its last point of implementation, through the governmental schemes to the reporting statements. The audit output must be accurate, timely, complete and balanced.

2.                  Our audit processes are, however, very target‐oriented. The quest for draft paragraphs has an overwhelming impact on the entire process of audit planning, implementation and reporting. The narration of an event of individual infraction is paramount: the enormous audit efforts through a very large quantum of substantive testing do not yield an overall audit opinion; trace the rupee; or help develop a syncretic view of the CAG on any sector or on overall governance and delivery of services. Despite the sheer spread of the CAG’s audit mandateand deploying such a large workforce, complete, accurate and timely reporting is yet to be achieved. Financial attest is the mainstay for every auditor. But it is placed very low in the priorities of an AG office and is the weakest link in the auditchain.

3.                  An audit report on government should, for an ordinary citizen, report for governance i.e., report on delivery of services, which is entirely different from reporting on departments. We certify figures for instance, UP spending around Rs 73,000 crore for developmentduring 2009‐10, which may not find resonance with ground realities. In the absence of norms fordisaggregation of components of expenditure to work out the delivery cost, we are not in a position to report the same to an ordinary citizen.


4.                    The fragmentation of audit is currently reflected in planning, execution and reporting. Fragmentation of audit by fitting audit resources into silos of transactions audit, central audit, performance audit, has led to gaps in audit, whereby large chunks of governmental activity is either not audited or is audited in a disparate manner that does not yield a comprehensive coverage.

Contours of a model: reporting for governance

5.                  The threshold and hence the most important stage is the audit plan. Each office must draw an annual audit plan integrating all streams of regularity audit‐ transactions, financial audit and central audit. A thematic approach will be necessitated to orient our reports towards governance. The audit should be planned with the ordinary citizen and the quality of governance he receives, in the centre stage. The box illustrates the possible themes for audit.











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Themes





Focus





Audit areas
Changing security





Internal security





Audit of Home Ministry
threats











Use of army; paramilitary forces in internal security












State Police












Judicial system
Changing nature of





Government as a





Audit of Regulatory functions
Governance





facilitator and





Audit of Non tax Receipts to ensure cost recovery






regulator



















Sustainability concerns





Financial health; use





Non Plan expenditure






of natural resources;





Fiscal policies






environment





Environment Audit






protection,





Mining; allocation of natural resources












Dispute resolution mechanisms












Agriculture












Science and Technology
Serving the underserved





Inclusive growth,





Tribal welfare






development of





Management of Forest areas






backward areas





Rural development and panchayati raj












Labour
Improving the quality of





Provisioning of





Health
life of citizens





services





Water












Education




Protecting financial

security of government

resources



Audit of Tax Revenues

Investment in Public Sector

Creation of Asset Register
FRBM



Food security

Sustaining provision

Procurement of food


of food

Research in agriculture and extension




Public distribution




Mid­day meals

The bases could also be districts/ constituencies /other geographical units eg: KBK districts in Orissa; CCOs/ departments/ directorates as a whole; or activities across CCOs eg: PPPs. A value‐added product, drawn from a strong attestation process, would be a report of the CAG on cost of delivery of basic services (gross/ per capita) across the States. We should, thus, be in a position to harness the strength of our audit reach.

6.                  An important consideration is that this basis should concurrently lend to drawing a sample that is fairly representative of the universe (so that a coherent, comprehensive audit opinion can be drawn) and that it should reflect areas of high risk in governance. While the annual budget will be the principal document that will be the template for the selection of the basis, the sources should be as broad‐based as possible. This requires collection of data relating to each programme/ scheme; research studies on the sector, plan documents, past reports etc.

7.                  The audit plan and the selection of the auditee units will need to be based on twin

requirements: the audit must provide an opinion on the theme and also meet the requirements of financial attest. Audit planning should be allocated 20% of the overall allocation of time and resources.









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8.                  Two parties will be deployed for every audit: the team for auditing particular department/CCO

should be the same. One of the teams will focus
only on internal controls that impact financial



HR

MR

LR


Period for

6 months

3 months
2

attest. The audit period will depend on the





Conducting Audit





months

number of DDOs proposed to be covered under

Number of DDOs to

10

6

4



be covered in the








each CCO during the year. For this purpose,
Department

departments can be categorised under high risk




(HR); medium risk (MR) and low risk (LR). The selection will not be on the need for equitable distribution across wings etc., but on the need to draw an audit opinion on the selected sample. 20% of the audit parties could be kept aside to cover other departmental CCOs (other than those selected for detailed thematic study during the yearbut will be important for the purpose of financial attest). The number of DDOs, if any, to be selected from these remaining departments will depend on manpower availability.


9.                  After the first year, the audited units automatically get shifted to a fourth new category under the sub category “HR Done”. Depending on the results of the audit of the selected B and C category units, the AG office can decide for a more extensive audit : for example if during the coverage of the Handloom department for two months it is felt that this is a potential unit which requires a further in depth analysis then more time could be devoted. Otherwise these departments get categorised into “LR done” and “MR done” category. Assuming that there are 40 departments in a State,the audit base of an office will be as illustrated below:

No. of departments
HRD
MR
LR
HR Done
MR
LR
Total





Done
Done

First Year
8
15
7
0
0
0
40
Second Year
6
11
5
2
4
2
40
Third Year
4
7
3
4
8
4
40

10.               In the second year, the audit of the units already covered will be mainly, a follow‐up on the control weaknesses identified in the first year of audit. Hence the allocation of party days to the units already covered will be proportionately lower, thus providing space for coverage of units that are yet “uncovered”. Within a period of 4‐5 years, all departments can get covered.

11.               Central audit could be the fulcrum for directing our audit efforts for financial attest. The centralaudit wing or the financialattest unit (FAU) will identify the risks specific to each area by analyzing the accounts; prepare the themes for the financial attest; co‐ordinate with the themes on other aspects (other than financial attest) in the area; select vouchers biased to those themes (or bases like CCOs) under check; receive Treasury inspection Reports from A&E offices; receive monthly appreciation notes issued by the A&E office etc. It will play a central role in audit planning. The concept of three‐phased audit could be introduced in financial attest of State governments as well. For instance, the central audit wing could issue (every quarter) the infractions that deviate from rules, for





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eg: nil payment vouchers that show transfer of plan funds to PDAs in 1st quarter, and request the State government to reverse the transfer, lest it should impact the final certification.

12.               The effectiveness of the audit report will be enhanced if the integration is reflected in the report. Our regularity audit is not geared to provide an overall opinion‐ this would appear to an outsider, as shying away from clear responsibility. The role of audit in identifying the risk of frauds and gross errors must be integrated and reflected in the audit products. Investigative audit geared to determining the risk of frauds, is currently weak. This is particularly important in new areas where government rules are inchoate or not adequate or where experiential wisdom is minimal. A value added product that we can add to our platter, would be a yearly appreciation of risks in identified sectors; it could be provided when there is change ofgovernment; or tailored as we so decide.

13.               Review of compliance with laws and regulations is important in public audit because rules provide the framework in which government decisions become transparent and against which, internal controls can be substantively checked. This is an important area of audit work and the assurance process; its place and importance need reiteration in an environment where rules and therefore, audit is seen as speed‐breakers or even as detrimental to innovation. The decision makers need to know if the laws are being followed, whether they have the desired results and if not, what revisions are necessary. The concept of materiality must also be suitably adopted in public audit. The qualitative aspects of materiality, measured by whether it could affect decisions of the legislature to continue a programme or grant funding‐ plays a greater role in public sector than in the private sector. The ISAsrecognize that “while misstatements of small monetary amounts may be deemed trivial, they may be related to compliance or internal control, and thus may not be seen as trivial.” Important in arriving at an audit opinion on whether the infraction is qualitatively material, is that auditor exercises his professional judgment, maintaining professional skepticism in his audit approach. A KD‐based approach often underestimates the importance of such judgment; there is a need to shift in the approach which allows the auditor to base his opinion on persuasive rather than conclusive audit evidence.

14.               The integrated audit requires that the field offices have considerable freedom in audit planning and implementation, free from the tyranny of numerical targets. In place of such targets that are so out of place in an assurance based audit process, we could strengthen the already existing mechanism of seeking an audit assurance‐ a report like an aide memoire, that will, with regard to each sub‐part of the audit plan, provide an audit opinion that will assure, qualify or draw attention to any specific risks. Care should be taken that processes automatically lead to such an aide memoire, without placing a strain on the AG office. We recommend automated software (e.g. Teammate) for use in audit planning and implementation. The rigour that exists in performance audit on documentation of working papers for all findings, regardless of whether the assurance is positive or negative) should be extended to regularity audit as well. This will also ensure accountability of field audit party and its members, at least, make assessment of their work, more objective.










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GLOSSARY OF TERMS







ABBREVIATION

EXPANSION







ADAI(C&AB)

ADDITIONAL DEPUTY COMPTROLLER & AUDITOR GENERAL (COMMERCIAL &



AUTONOMOUS BODIES)


AG (AUDIT)

ACCOUNTANT GENERAL, AUDIT


AG (A&E)

ACCOUNTANT GENERAL, ACCOUNTS & ENTITLEMENTS


BI

BUSINESS INTELLIGENCE


CAP – CASS

CENTRAL AUDIT PARTY – CENTRAL AUDIT SUPPORT SECTION


CCO

CADRE CONROLLING OFFICER

CFRA

COMBINED FINANCE & REVENUE ACCOUNTS



CONCOR

CONTAINER CORPORATION OF INDIA


COPU

COMMITTEE ON PUBLIC UNDERTAKINGS


CSS

CENTRAL SECRETARIAT SERVICE


DAI

DEPUTY COMPTROLLER & AUDITOR GENERAL


DAI(C)

DEPUTY COMPTROLLER & AUDITOR GENERAL (COMMERCIAL)


DAI(LB&A)

DEPUTY COMPTROLLER & AUDITOR GENERAL (LOCAL BODIES & ACCOUNTS)


DAI(RA)

DEPUTY COMPTROLLER & AUDITOR GENERAL (RECEIPT AUDIT)


DAI(RC)

DEPUTY COMPTROLLER & AUDITOR GENERAL (REPORT CENTRAL)


DG

DIRECTOR GENERAL


DG (P&T)

DIRECTOR GENERAL, POSTS & TELECOMMUNICATIONS


DGA (CE)

DIRECTOR GENERAL OF AUDIT, CENTRAL EXPENDITURE


DGA (CR)

DIRECTOR GENERAL OF AUDIT,CENTRAL RECEIPT


DRDO

DEFENCE RESEARCH AND DEVELOPMENT ORGANISATION


GOI

GOVERNMENT OF INDIA


HOD

HEAD OF DEPARTMENT


IAAD

INDIAN AUDIT AND ACCOUNTS DEPARTMENT


IAAS

INDIAN AUDIT AND ACCOUNTS SERVICES


IFRS

INTERNATIONAL FINANCIAL REPORTING STANDARD


IRCON

INDIAN RAILWAY CONSTRUCTION COMPANY


IRs

INSPECTION REPORTS


IT

INFORMATION TECHNOLOGY


KBK

KALAHANDI‐BOLANGIR‐KORAPUT


MAB

MEMBER AUDIT BOARD


NGO

NON‐GOVERNMENTAL ORGANISATION


PAC

PUBLIC ACCOUNTS COMMITTEE


PAG

PRINCIPAL ACCOUNTANT GENERAL


PAO

PAY AND ACCOUNTS OFFICER


PD

PRINCIPAL DIRECTOR


PDA (AF&N)

PRINCIPAL DIRECTOR OF AUDIT, AIR FORCE & NAVY


PDA (E&SM)

PRINCIPAL DIRECTOR OF AUDIT, ECONOMIC & SERVICE MINISTRIES


PDA (OF)

PRINCIPAL DIRECTOR OF AUDIT, ORDNANCE FACTORIES


PDA (SD)

PRINCIPAL DIRECTOR OF AUDIT SCIENTIFIC DEPARTMENT


PR.PAO

PRINCIPAL PAY AND ACCOUNTS OFFICER


PRI

PANCHAYATIRAJ INSTITUTION






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PSU

PUBLIC SECTOR UNDERTAKINGS
RITES

RAIL INDIA TECHNICAL ENGINEERING SERVICES
RTI

REGIONAL TRAINING INSTITUTE
ULB

URBAN LOCAL BODY
UTs

UNION TERRITORIES
VFM

VALUE FOR MONEY
VLC

VOUCHER LEVEL COMPUTERISATION
VPN

VOICE PHONE NETWORK





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