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A. Facts of the Case
1. A company is a public sector enterprise under the administrative control of the Ministry of Mines, Government of India and is engaged in mining of bauxite, manufacturing of alumina and aluminium, generation of power at captive power plant for use in Smelter Plant. The saleable products derived out of the manufacturing process are alumina and aluminium which are sold in domestic and international markets. The company has four production units (i) A fully mechanised open cast Bauxite Mine having excavation capacity of 48,00,000 tonnes per annum, (ii) Alumina Refinery having production capacity of 15,75,000 tonnes per annum, (iii) Captive Power Plant having 8 units of 120 MW each to generate power and (iv) Smelter Plant of 3,45,000 M.T. per annum capacity.
2. Mines division serves feed-stock to the Alumina Refinery, located at 16 KM downhill. The Refinery provides alumina to the company’s Smelter Plant which is about 600 KM away, in a specially designed alumina wagon by rail transport. For production of 1 M.T. of aluminium metal at Smelter, 13600 KWH of power is required, which is met by generation of power at Captive Power Plant situated at a distance of 4 KM. Cost of power constitutes about 30% of the cost of production of aluminium. Captive Power Plant is set up exclusively to supply un-interrupted power to Smelter. It is also connected to State grid, to take care of the supply of emergency power to Smelter in case of any break-down or failure at the Captive Power Plant. Any surplus power after meeting the requirement of Smelter is automatically transmitted to State grid and treated as sale.
3. The company has identified the following three reportable segments on the basis of type of products:
(i) Chemical Segment - For Bauxite Mining and Alumina Plant.
(ii) Power Segment - For Captive Power Plant.
(iii) Aluminium - For Smelter Plant.
4. At Alumina Refinery, the company has set up two value added plants for (i) special grade hydrate and (ii) special grade alumina (SGA). Both the units have been identified as cash-generating units for the purpose of Accounting Standard (AS) 28, ‘Impairment of Assets’.
5. The installed capacity of the SGA plant is 19400 MT per annum. On its way to stabilisation and entering into the new market, the capacity utilisation during the period from the financial year 2005-06 to 2007-08 ranged from 8.23% to 21.65% only. During the course of audit for the financial year 2008-09, the Comptroller and Auditor General of India (C&AG) auditors advised for calculating recoverable amount of SGA plant for the purpose of testing impairment.
6. The querist has stated that estimate of future cash flows over the useful life of the SGA plant, i.e., upto the financial year 2022-23 was made in line with the provisions of paragraphs 26(a), 26(b), 26(c), 27, 28, 29, 30, 31(a), 31(b), and 31(c) of AS 28. Present value of the cash flows worked out to be positive as compared to the carrying cost of the assets. For SGA plant, calcined alumina, which is internally transferred, is the only raw-material. While calculating the cash flows, cost of production of calcined alumina was considered as the cost of raw-material. The querist has further stated that calcined alumina which is internally transferred to Smelter Plant for production of aluminium metal is valued at cost although about 50% of production of alumina is sold.
7. As per the querist, during the course of scrutiny/checking of cash flow statement, C&AG auditors agreed to each and every assumption taken, except the cost of raw-materials. In support of their views, C&AG auditors relied upon the following provisions of paragraph 68 of AS 28:
“68. If an active market exists for the output produced by an asset or a group of assets, this asset or group of assets should be identified as a separate cash-generating unit, even if some or all of the output is used internally. If this is the case, management’s best estimate of future market prices for the output should be used:
(a) in determining the value in use of this cash-generating unit, when estimating the future cash inflows that relate to the internal use of the output ; and
(b) in determining the value in use of other cash-generating units of the reporting enterprise, when estimating the future cash outflows that relate to the internal use of the output.”
In the opinion of the C&AG auditors, market price of calcined alumina should have been taken as the cost of raw-material instead of cost of production. This resulted into negative cash flows necessitating making provision for impairment loss.
8. The querist has stated that in reply to the C&AG’s query, as stated in paragraph 7 above, the management justified its calculation as per paragraph 31(b) of AS 28, which reads as follows:
“31. Estimates of future cash flows should include:
(a) projections of cash inflows from the continuing use of the asset;
(b) projections of cash outflows that are necessarily incurred to generate the cash inflows from continuing use of the asset (including cash outflows to prepare the asset for use) and that can be directly attributed, or allocated on a reasonable and consistent basis, to the asset; and
(c) net cash flows, if any, to be received (or paid) for the disposal of the asset at the end of its useful life.”
9. According to the querist, C&AG auditors were of the view that there seems to be a contradiction between the provisions of paragraph 31 and paragraph 68 of AS 28 and advised to seek opinion from the Expert Advisory Committee of the Institute of Chartered Accountants of India.
B. Query
10. Based on the facts stated above, the opinion of the Expert Advisory Committee has been sought by the querist on the issue as to whether the raw-materials’ cost (internally transferred) should be taken at ‘cost of production’ or at ‘market price’ for the purpose of calculating future cash flows for ascertaining impairment as per AS 28.
C. Points considered by the Committee
11. The Committee notes that the basic issue raised by the querist is that whether, for the purpose of calculating future cash flows while testing for impairment, the price of the raw-material which is transferred internally, should be taken at ‘cost of production’ or ‘market price’. The Committee has, therefore, examined only this issue, and has not examined any other issue that may arise from the Facts of the Case, such as, whether the cash generating units are properly identified by the company, etc. The Committee presumes that all other factors for determining future cash flows/value in use of the CGU have been duly considered by the company in accordance with AS 28. The Committee notes from the Facts of the Case that it is not clear whether ‘calcined alumina’ is the raw-material for the SGA plant or for Smelter Plant. However, since the opinion of the Committee contained hereinafter is based on the principles of pricing of internally transferred raw-materials, it does not affect the opinion.
12. The Committee notes paragraph 31 of AS 28 reproduced in paragraph 8 above and paragraph 68 of AS 28 reproduced in paragraph 7 above. The Committee further notes paragraph 69 of AS 28 which states as below:
“69. Even if part or all of the output produced by an asset or a group of assets is used by other units of the reporting enterprise (for example, products at an intermediate stage of a production process), this asset or group of assets forms a separate cash-generating unit if the enterprise could sell this output in an active market. This is because this asset or group of assets could generate cash inflows from continuing use that would be largely independent of the cash inflows from other assets or group of assets. …”
13. From the above, the Committee is of the view that paragraph 31 of AS 28 lays down the composition of the estimates of future cash flows. Paragraph 31(b) of AS 28 only lays down that the projections of cash flows for an asset should include cash outflows required to generate cash inflows. This paragraph further requires that cash outflows should include among other expenses, overheads and other related charges that can be directly attributed or allocated on a reasonable and consistent basis to the asset.
14. The Committee is of the view that, on the other hand, paragraph 68 of AS 28 lays down the parameters for identification of the cash-generating unit in case when an active market exists for the output produced by the asset or a group of assets even if the output is used internally. This paragraph requires that in such a situation, that is, when an active market exists for the output of an asset or a group of assets which is used internally, that asset or group of assets should be identified as a separate cash generating unit. This paragraph further requires that in such a situation, it is the management’s best estimate of future market prices of the output that should be used for determining the cash inflows even from internal use of the output. Similarly, for determining the cash outflows of the cash generating unit that uses the output of this CGU as its raw material, it is the management’s best estimate of future market prices of the product that should be used for determining cash outflows.
15. From paragraphs 13 and 14 above, the Committee is of the view that paragraph 31(b) is a general paragraph which deals with what cash outflows should be taken into account while determining future cash flows; whereas, paragraph 68 of AS 28 contains specific requirement with respect to, inter alia, the price at which the raw material which is transferred internally, should be taken for the purpose of determining cash outflows. Thus, in the view of the Committee, there is no contradiction between paragraphs 31 and 68 of AS 28.
D. Opinion
16. On the basis of the above and subject to paragraph 11 above, the Committee is of the opinion that for the purpose of calculating future cash flows for determining impairment as per AS 28, the cost of the internally transferred raw-material should be taken at the management’s best estimate of future market prices of the output (raw material).
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