Expert Advisory Committee
ICAI-Expert Advisory Committee
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Query No. 22

 

Subject:           

Valuation of investments.1

 

A. Facts  of  the  Case

1. A  public  sector  company  is  engaged  in  the  business  of  refining, transportation and marketing of petroleum products.  During the financial year ended March 31, 2002, the company acquired controlling interest from Government of India in another public sector undertaking (hereinafter referred to as the ‘acquired company’) @ Rs. 1,551 per share as against the book value of Rs. 192.58 per share and market value of Rs. 876 per share as on February 18, 2002.

 

2. The acquired company is a stand-alone marketing company and since inception, it has been predominantly operating in the retail segment having 1,553 retail outlets and overall market share of 4.3% of all products combined and 7.8% market share in MS and 9.3% in HSD and turnover of Rs. 8,453 crore during the year 2001-02.

 

3. As per the querist, the strategic premium of Rs. 675 per share has been paid considering various tangible and intangible factors such as:

 

        (a)        Maintaining the current market share.

 

        (b)        Avoidance of erosion of refining volume currently supplied to acquired company.

 

        (c)        Higher refinery throughput.

 

        (d)        Significant potential to add value to the existing retail marketing capabilities.

 

        (e)        Higher retail volume thereby providing stability to cash flow, as the retail sale is less susceptible to risk as compared to bulk                     sale.

 

        (f)         Retail margins are relatively insulated as compared to bulk sales.

 

        (g)        Access to positive cash flow and zero debt company – significant leverage to raise debt.

 

Further, in a deregulated environment, generation of additional business volume through new retail outlets will in no way be comparable with the volumes being achieved by the existing 1,553 retail outlets of the acquired company. Also, if 1,553 retail outlets are opened by the acquiring company, the cost would be phenomenal.  In view of the above factors, the purchase price of Rs. 1,551 per share was offered to Government of India considering the long-term perspective.

 

4. The above investment in the shares of the acquired company has been considered  as  long  term/strategic  investment  and,  therefore,  has  been accounted for at cost, i.e., at Rs. 1,551 per share in the financial statements. No provision for diminution in value has been made in the books of account as per the accounting policy which is as under:

 

“All long term investments are valued at cost and provision for diminution in value thereof is made, wherever such diminution is not temporary.”

 

As per the requirement of Schedule VI to the Companies Act, 1956, the aggregate market value of the quoted shares has been properly reflected in the financial statements.

 

5. The querist has drawn attention of the Committee to paragraph 17 of Accounting Standard (AS) 13, ‘Accounting for Investments’, which states as under:

 

“17. Long-term investments are usually carried at cost.  However, when there is a decline, other than temporary, in the value of a long term investment, the carrying amount is reduced to recognise the decline. Indicators of the value of an investment are obtained by reference to its market value, the investee’s assets and results and the expected cash flows from the investment.  The type and extent of the investor’s stake in the investee are also taken into account. ….”

 

According to the querist, it is evident from the above that the market value is not the single indicator to judge the value of the investment. Certain other factors such as the investee’s assets, results and the expected cash flows from the investment are also to be considered in addition to the market value in order to ascertain the value of such investment.

 

6. On March 28, 2002, the acquired shares were quoted at Rs. 880 per   share on NSE and the current market price as on July 18, 2002, was around Rs. 300.

 

7. Considering the tangible and intangible benefits as explained above, in the view of the management, there is no permanent diminution in the value of the strategic investment in the acquired company as the same has been considered as a long term investment.  Therefore, as per the querist, there is no need for provision for diminution in the value of the shares of the acquired company.

 

B. Query

 

8. The querist has sought the opinion of the Expert Advisory Committee on the following issues:

 

        (a)        Whether the accounting treatment ‘at cost’ under the head ‘Long Term Investments’ without providing for any diminution                      in value is correct and in accordance with the provisions of AS 13.

 

        (b)        If not, what should have been the accounting treatment in such a situation particularly considering the fact that there is no                      material change in the circumstances and strength of the acquired company further supported by the expected benefits                      from such synergy. Whether the reduction in market value should be considered in isolation for ascertaining the value of                      such an investment.  What methodology should be adopted for ascertaining the provision for diminution in the value of                      investment, if any.

 

        (c)        If any provision for diminution in the value is to be made, whether such provision should be charged to the profit and loss                      account or whether the same can be considered as deferred expenditure and amortised over a period of 3 to 5 years.                              Whether it is open for the company to charge off such diminution in the value in the books of account instead of creating a                      provision.

 

        (d)        Whether the premium paid for strategic benefits for investment described in the facts of the case, can be accounted for                      separately in the books of account keeping in view that AS 13 specifies that long term investments should be recorded at                      cost and there is no specific provision in the Standard in respect of accounting for premium paid for strategic benefits.

 

C. Points  considered  by  the  Committee

 

9. The Committee notes from the facts of the case that the company has acquired shares of another company for strategic reasons which it intends to hold for a long period.  Accordingly, the Committee is of the view that the investment should be classified as a long term investment in the separate financial statements of the company.

 

10. The Committee notes paragraph 17 of AS 13, reproduced at paragraph 5 above, and paragraph 32 of AS 13, which provides as below:

 

“ 3 2 . Investments classified as long term investments should be carried in the financial statements at cost. However, provision for diminution  shall  be  made  to  recognise  a  decline,  other  than temporary, in the value of the investments, such reduction being determined  and  made  for  each  investment  individually.”

 

11. On the basis of the above, the Committee is of the view that in case of long-term investments only where there is a decline, other than temporary, in the value of investments, the carrying amount thereof is reduced to recognise the decline.  The Committee is further of the view that to determine whether there is  a decline  other  than  temporary,  in  the  value  of investments,  an assessment  should  be  made  keeping  in  view  the  assets  of  the  acquired company, its results, the expected cash flows from the investment, etc. The market value of the shares is not the sole indicator of decline, other than temporary, in the value of investments.

 

12. On the question whether the provision for diminution in the value of long term investments should be made by way of a charge to the profit and loss account or whether the same can be considered as deferred expenditure and amortised over a period of 3 to 5 years, the Committee notes paragraph 33 of AS 13, which provides as below:

 

“ 3 3 . Any reduction in the carrying amount and any reversals of such reductions should be charged or credited to the profit and loss  statement.”

 

D. Opinion

 

13. On the basis of the above, the Committee is of the following opinion on the issues raised in paragraph 8:

 

        (a)        The accounting treatment ‘at cost’ under the head ‘Long Term Investments’ in the separate financial statements of the                            company, without providing for any diminution in value is correct and is in accordance with the provisions of AS 13                             provided there is no decline, other than temporary, in the value of investments.

 

        (b )       If the decline in the value of investments is not other tha n temporary, compared to the time when the shares were                               purchased, no provision is required to be made.  The reduction in market value should not be considered in isolation to                            determine the decline, other than temporary. The amount of the provision for diminution in the value of investment                               may be  ascertained by considering the factors indicated in paragraph 17 of AS 13 reproduced above.

 

        (c)        The provision for diminution in the value of investment should be created as a charge to the profit and loss statement.  As                     per the requirements of AS 13, the diminution in the value of investment can neither be accounted for as a deferred revenue                     expenditure nor it can be written-off in the statement of profit and loss.

 

        (d)        The long term investments should be carried at cost as per the requirements of AS 13.  The amount paid over and above the                     market price can not be accounted for separately.  

 

1  Opinion finalised by the Committee on 20.1.2003.