Expert Advisory Committee
ICAI-Expert Advisory Committee
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Query No. 24

 

Subject:          

  Capitalisation of completed parts of a project.1

 

A. Facts  of  the  Case

 

1. Two companies (company ‘A’ and company ‘B’) have been jointly promoted by both the Central Government and a State Government.  The companies are setting up an integrated iron and steel plant for manufacture of 4.92 lakh tonnes per annum (tpa) basic grade pig iron, 2.76 lakh tpa steel billets and 3.00 lakh tpa steel wire rods. The entire work under the project has  been  broken  into  several  packages  most  of  which  are  interlinked/ interdependent in nature except few independent packages like guest house, staff residential quarters, dispensary, inter-plant road, area lighting packages, etc. Major packages company-wise, are as under:

 

Company A

Company B

Phase – I :

Main Packages

Ancillary Packages

Main Packages

Ancillary Packages

 

a)  Blast Furnace

(BF)

b)  Sintering Plant

c)  Raw Material

Handling

System

d)  Pig Casting

Machine

 

a)  Raw Water

Treatment Plant

b)  Railway Facilities

including

In-motion Rail

Weighbridge

c)  Plant Water

Supply Facilities d)  Road

Weighbridge

 

a)  Coke Oven

Plant

b)  Power Plant

 

a) By-products Plant

b) Nitrogen Plant

 

Phase – II :

Steel Making Facilities comprising of To p  B lo wing  Oxygen  Co nver ter s, Oxygen Lancing System, Gas Recovery and  Cleaning  Unit,  Ladle  Refining Furnace,  Tundish  and  Strand  Billet Caster.

2. Although separate areas have been earmarked for both the companies (i.e., land measuring 2250 acres and 250 acres have been registered separately  in  the  names  of  company  ‘A’ and  company  ‘B’ respectively),  both  the companies  are  within  the  common  compound  wall  considering  the interdependence between the companies.

 

3. The process of manufacturing for both the companies on composite basis includes sintering, iron making and steel making. Various inputs required for  this  manufacturing process  are  iron ore  fines,  iron  ore  lumps,  coke, manganese ore, quartzite, limestone, dolomite and coke breeze.   Iron ore fines, limestone, dolomite and coke breeze are processed through Sinter Plant to produce BF sinter which becomes a major raw material for Blast Furnace. BF sinter together with iron ore lump, BF coke (from Coke Oven Plant), manganese  ore,  quartzite  and  oxygen  are  then processed  through BF  to produce hot metal.  About 47% of the hot metal goes to pig casting machine for production of Pig Iron while the balance hot metal is to be used as raw material alongwith other inputs like iron ore, burnt lime, slag, bauxite and iron scrap for production of steel by the Steel Making Shop comprising Basic Oxygen Furnace, Gas Cleaning Plant, Continuous Casting Plant, etc.

 

4. Company ‘A’ and company ‘B’ are interdependent on each other in the following manner:

 

Coke

 

The  total  requirement  of  coke  of  company  ‘A’ would  be  sourced  from company ‘B’ which is setting up a Coke Oven Plant with an installed capacity of 8.11 lakh tpa of BF grade coke.

 

Power

 

About 85% of energy requirement of company ‘A’ would be met from the Power Plant (60 MW) of company ‘B’. This Power Plant shall use BF gas of company ‘A’ and Coke Oven gas of company ‘B’ for its operation.

 

Present  status  of  packages:      

Package   Progress
Interdependent  Packages
       Blast Furnace    Commissioned on 02.02.2002 although some minor work is pending

Sinter Plant

About 85% of work is complete and

is yet to be commissioned.

Raw Material Handling System

Commissioned on 02.02.2002 although some minor work is pending.

Pig Casting Machine

Commissioned on 02.02.2002.

Steel Making Facilities

Only 16% of work is complete and is yet to be commissioned.

Coke Oven Complex

About 70% of work is complete and is yet to be commissioned.

Power Plant

One out of three units of power plant has been commissioned on 16.04.2002.

Ancillary  Packages

Raw Water Treatment Plant

Out of two units, one unit meant for BF is complete and is in use. The other one is yet to be commissioned.

Railway facilities including In-

motion Rail Weighbridge

Out of double lines, single line is

ready and is in use. In-motion Rail Weighbridge is ready but Preliminary and Final Acceptance Certificates

(PAC and FAC) are yet to be issued.

Plant Water Supply Facility starting

from sourcing the water from river

upto the end use station at plant site.

About 66% of work is complete

and is yet to be commissioned.

Road Weighbridge

Fully completed and is in use.

By-product Plant

About 25% of work is complete and is yet to be commissioned.

Nitrogen Plant

One out of two units is complete and is in use.

Independent  Packages

 

Guest house

The possession of the house has been taken and the same is being used  although the completion certificate has not been issued to the contractor. Thus, 10% of the contract price has been retained.

Staff Residential Quarters

Out of 9 blocks consisting of 96 quarters, 5 blocks consisting of 56 quarters have been handed over by the contractor and occupied by the employees. Remaining 4 blocks are under construction.

Inter-plant Road and Lighting

Complete and are in use.

Dispensary

Complete and is in use.

 

 

5. The salient features of the agreement between the two companies are as below:

 

        (a)        The transfer price of coke will be the same as the CIF cost of imported coke of equivalent specifications at the time of transfer.

 

        (b)        Company ‘B’ shall have no right to sell electricity to a third party without the concurrence of company ‘A’. The power tariff payable by                              company ‘A’ to company ‘B’ shall, in any case, and always be less than or equal to that of the State’s power distribution corporation.

 

        (c)        Both the companies shall have the right to sell their products (except sale of power by company ‘B’) to a third party subject to first right of                      refusal by the other company. Price of such products for sale to a third party shall not be less than the price being charged from each other.

 

        (d)        Both the companies shall not resell the product and services purchased from each other without written permission.

 

        (e)        Cost of common facilities such as infrastructure facilities shall be shared by both the companies on pro-rata basis, taking into account the                             capital cost of both the units.

 

        (f)         Both the companies shall mutually discuss and finalise any change in tariff rates of any of the products and services at the time of                                      commencement of commercial production.

 

        (g)        Both the companies shall supply the products and services as per the quantities stipulated and finalised between the companies.

 

        (h)        The agreement includes obligation of both the companies in respect of completion of work/facilities by the companies.

 

6. The present operational status of the project is that the Blast Furnace (BF) has been commissioned on 02.02.2002. The capacity of BF, when sinter is used, is 3,000 MT per day. Currently, the BF is using all materials like iron ore-lump (100%), coke, dolomite, limestone, manganese ore and quartzite to produce pig iron instead of using sinter (80%) from sinter plant, iron ore- lump (20%), manganese ore and quartzite. The BF is not yielding desired output since it is sinter based (as stated above) and the sinter plant is yet to be completed. Further, charging 100% iron ore-lump to BF without using sinter is detrimental to the health of BF in the long run. Present production of BF ranges between 900 tonnes to 1,200 tonnes per day against the rated capacity of 3,000 tonnes per day resulting in capacity utilisation of only 30% to 40% since the operation of BF has not been stabilised. Similarly, since coke oven plant is not yet ready, the required coke for BF is being procured from outside. Power plant is generating power in the range of 7 to 10 MW against the envisaged capacity of 60 MW since only one out of three units has been made operational on 16.04.2002. Further, as the Plant Water Supply Facility is incomplete, water requirement of the plant is being met by hiring the water supply facility of some other company. From April 2002 to September 2002,  company  ‘A’ has  sold  approximately Rs.100  crore  of  pig iron  at competitive rates both in domestic as well as foreign markets and Rs. 3.6 crore of BF gas to company ‘B’. Similarly company ‘B’ has sold approximately Rs. 7 crore of steam and Rs. 3 crore of power to company ‘A’ during the aforesaid period.

 

7. According to the querist, on the basis of considerations given below, company ‘A’ has not  capitalised  the  expenditure incurred  on  any  of the packages.  The expenses incurred on operation are being treated as  ‘trial and test run expenses’ which are being grouped as  ‘Incidental Expenditure During Construction’, after netting off sales revenues and other income during the financial year 2001-2002, on the following considerations:

 

        (a)        The BF is sinter-based and sinter plant is not ready. The capacity of BF is, thus, under-utilised.

 

        (b)        Even after successful commissioning of sinter plant, capacity of BF can not be raised to 100% owing to capacity constraint of pig casting                             machine which can use only 47% of hot metal from BF and balance hot metal to be used by Steel Making Shop, which is   incomplete. Thus,                     BF is not commercially expedient in a practicable manner.

 

        (c)        Ancillary packages such as Railway Facilities, Plant Water Supply System, etc., are not ready.

 

B . Query

 

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

 

(a)  For  company  A

 

        (i)         Whether it is necessary to capitalise commissioned packages like Blast Furnace, Raw Material Handling System and Pig Casting Machine in                      isolation since the same have been commissioned pending the capitalisation of remaining incomplete packages like Sinter Plant, Steel Making                      Shop and ancillary packages.

 

        (ii)        If the answer to (i) above is in the affirmative, then fro m which date the capitalisation should have been done and on what basis the incidental                     expenditure during construction should have been allocated.

 

        (iii)        If the answer to (i) above is in the negative, then at wh at stage the capitalisation is to be done, i.e., whether after commissioning of Sinter Plant                     or after commissioning of both Sinter Plant and Steel Making Shop or after complete integration of all the packages of both the companies.

 

        (iv)        In case of certain independent packages like guest house, staff quarters, inter-plant roads and lighting and dispensary (as mentioned above)                     which are complete, whether it is necessary to capitalise the same pending capitalisation of main packages.

 

(b) For  company  B

 

        (i)         Whether it is necessary to capitalise one unit (out of three units) of Power Plant and one unit (out of two units) of  Nitrogen Plant which have                     been made operational ignoring the remaining two units of Power Plant, one unit of Nitrogen Plant and Coke Oven Plant which are incomplete.

 

        (ii)        If the answer to (i) above is in the affirmative, then fro m which date the capitalisation should have been done and on what basis the incidental                     expenditure during construction should have been allocated.

 

        (iii)        If the answer to (i) above is in the negative, then at wha t stage the capitalisation is to be done, i.e., whether after commissioning of remaining                      two units of Power Plant (i.e., Power Plant as a whole) or after commissioning of bo th Power Plant as a whole and Coke Oven Plant or after                      complete integration of all the packages of both the companies.

 

(c)  Common

 

        (i)         Whether main packages can be capitalised pending the capitalisation of ancillary packages or vice-versa.

 

        (ii)        After part capitalisation, how the general overheads, administrative overheads, etc., should be segregated for charging the same to the profit and                      loss account and allocated for expenditure during construction.

 

        (iii)        How the depreciation on infrastructure facilities like roads, buildings, etc., should be allocated to profit and loss account and expenditure during                      construction.

 

C. Points  considered  by  the  Committee

 

9. The Committee notes that in both the companies, i.e., company ‘A’ and company ‘B’, only some of the plants of the main packages and ancillary packages have been completed and commissioned. The Committee also notes that in respect of the Blast Furnace of company ‘A’ production has been started although the capacity utilisation is only 30% to 40%. The Committee also notes that this production is being achieved by purchasing alternative material from outside.  In respect of company ‘B’, the Committee notes that out of the 3 units of the power plant, only one unit is complete and producing power. Coke oven plant of company ‘B’ is not yet complete. The Committee also notes that some of the ancillary units and other constructions such as guest house, staff residential quarters are also complete fully/partly.  The Committee further notes that the companies are treating the expenses incurred on operation as trial and test run expenses.

 

10. The Committee is of the view that the purpose of the trial and test run is  to  ensure  that  the  plant  is  technically  complete  so  as  to  commence commercial  production.   During test  and  trial  run  if  there  are  technical deficiencies, adjustments are made in the plant so that it may run as intended. In the present case, it does not seem that the plants which are in operation are being run with the objective of ensuring that the plant is technically complete. The production being achieved from the plant is sold at competitive rates.  The Committee is of the view that the mere fact that the full capacity utilisation has not yet reached does not indicate that the plant is under trial and test run.

 

11. The issue as to whether part of a plant can be separately capitalised or not has been addressed in paragraph 21 of Accounting Standard (AS) 16, ‘Borrowing Costs’, issued by the Institute of Chartered Accountants of India, although from the point of view of the borrowing costs only. The Committee is of the view that the principle enunciated in that paragraph can be applied to other expenditures also.  Paragraph 21 of AS 16 is reproduced below:

 

“ 21 . When the construction of a qualifying asset is completed in parts and a completed part is capable of being used while construction continues for the other parts, capitalisation of borrowing costs in relation to a part should cease when substantially all the activities necessary  to prepare  that  part for  its intended  use  or sale  ar e complete.”

 

From the above, the Committee is of the view that those parts which are ready to commence commercial production or are ready for their intended use and can be operated independently of the remaining parts, should be considered to be ready for commencement of commercial production/intended use.

 

D. Opinion

 

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

 

(a) For  company  A

 

        (i)         In the given facts of the case, it is necessary to capitalise commissioned packages like Blast Furnace, Raw Material Handling System and Pig                     Casting Machine.

 

        (ii)        The date of capitalisation should be the respective dates on which the aforesaid packages were ready to commence commercial production.                       The incidental expenses during construction incurred upto that stage should be allocated to the commissioned packages on appropriate basis as                      indicated in paragraph 15 of the ‘Guidance Note on Treatment of Expenditure During Construction Period’, issued by the Institute of Chartered                      Accountants of India.

 

        (iii)        Since the answer to (i) above is in the affirmative, the question does not arise.

 

        (iv)        The independent packages like guest house, residential staff quarters, inter-plant roads and lighting and dispensary, which are complete should                      also be capitalised when they are ready for their intended use even though the capitalisation of some of the main packages is pending.

 

(b) For  company  B

 

        (i)         It is necessary to capitalise one unit of power plant and one unit of nitrogen plant which have been made operational.

 

        (ii)        The date of capitalisation should be the respective dates on which the aforesaid packages were ready to commence commercial production.                       The incidental expenses during construction incurred upto that stage should be allocated to the commissioned packages on appropriate basis as                      indicated in paragraph 15 of the ‘Guidance Note on Treatment of Expenditure During Construction Period’, issued by the Institute of Chartered                      Accountants of India.

 

        (iii)    Since the answer to (i) above is in the affirmative, the question does not arise.

 

(c) Common

 

        (i)         The main packages should be capitalised pending the capitalisation of ancillary packages or vice-versa, when it is considered that the same are                      ready to commence commercial production independent of each other or are ready for their intended use.

 

        (ii)        After part capitalisation, general overheads, administrative overheads, etc., should be segregated on an appropriate basis for charging the same                      to the profit and loss account and to the expenditure during construction account.

 

        (iii)        Similarly, depreciation on infrastructural facilities like roads, buildings, etc., should be allocated to profit and loss account and expenditure                              during construction account on an appropriate basis.

1  Opinion finalised by the Committee on 20.1.2003.