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REAL ESTATE (REGULATION AND DEVELOPMENT) ACT, 2016
FORM – 3 Chartered Accountant’s Certificate As amended on 31st May 2019
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FORM 3 Amendment
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RERA Form 3 Under RERA Changes brought in through Amendment 5 of the Regulations Gujarat RERA2019/Gen.Reg./Amdt 5. dated 31st May 2019 The certificates to be issued by the project architect, project engineer, chartered accountant in practice appointed by the promoter, for project Registration/Alteration/Extension, Quarterly Project Progress Report and for withdrawal of money from the separate account maintained under section 4(2) (l) (D) shall be in Form 1, 2 and 3 respectively. The Form 3 shall be submitted electronically on GujRERA Portal. The certifying professional has to affix his digital signature using utility on GujRERA portal accordingly. The electronic submission of these forms shall be applicable when the same is made available on GujRERA Portal.” (From 8th June 2019) Form 2 and Form 3 have been substituted and new formats have been notified.
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FORM 3 UNDERSTANDING THE FORMAT
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Format FORM 3 (See Regulation 3)
CHARTERED ACCOUNTANTS CERTIFICATE (On Letter Head) (FOR REGISTRATION OF A PROJECT AND SUBSEQUENT WITHDRAWL OF MONEY) Cost of Real Estate Project GujRERA Registration No: PR/GJ/_________________ Project Name Sr. No Particulars Amount (in Rs.) Estimated Incurred & Paid (Column - A) (Column - B) 1 (i) Land Cost: a Acquisition Cost of Land * or Development Rights, lease Premium, lease rent, interest cost incurred or payable on Land Cost and legal cost - - b Amount of Premium payable to obtain development rights, FSI, additional FSI, fungible area and any other incentive under DCR from Local Authority or State Government or any Statutory Authority c Acquisition cost of TDR (if any) d Amounts payable to State Government or competent authority or any other statutory authority of the State or Central Government towards stamp duty, transfer charges, registration fees etc. e Land Premium payable as per annual statement of rates (ASR) for redevelopment of land owned by Public Authorities. f Under Redevelopment / Rehabilitation Scheme: Estimated construction cost of redevelopment / rehab building including site development and infrastructure for the same as certified by Engineer (in Column-A) (ii) Actual Cost of construction of redevelopment / rehab building incurred as per the books of accounts as verified by the CA (in Column-B) Note: (for total cost of construction incurred, Minimum of (i) or (ii) is to be considered)
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Use of Market Value as a measure of Cost Incurred and Paid
Rule 3 (6) of General Rules - The promoter shall disclose,- estimated cost of real estate project as envisaged by the promoter by bifurcating the same into the market value of the land/ lease charges (as determined by the Government Approved Valuer). When will a promoter opt to disclose market value of land? S S Bhansali & Co Chartered Accountants FORM 3 Format FORM 3 (See Regulation 3) CHARTERED ACCOUNTANTS CERTIFICATE (On Letter Head) (FOR REGISTRATION OF A PROJECT AND SUBSEQUENT WITHDRAWL OF MONEY) Cost of Real Estate Project GujRERA Registration No: PR/GJ/_________________ Project Name Sr. No Particulars Amount (in Rs.) Estimated Incurred & Paid (Column - A) (Column - B) 1 (i) Land Cost: a Acquisition Cost of Land or Development Rights, lease Premium, lease rent, interest cost incurred or payable on Land Cost and legal cost - - b Amount of Premium payable to obtain development rights, FSI, additional FSI, fungible area and any other incentive under DCR from Local Authority or State Government or any Statutory Authority c Acquisition cost of TDR (if any) d Amounts payable to State Government or competent authority or any other statutory authority of the State or Central Government towards stamp duty, transfer charges, registration fees etc. e Land Premium payable as per annual statement of rates (ASR) for redevelopment of land owned by Public Authorities. f Under Redevelopment / Rehabilitation Scheme: Estimated construction cost of redevelopment / rehab building including site development and infrastructure for the same as certified by Engineer (in Column-A) (ii) Actual Cost of construction of redevelopment / rehab building incurred as per the books of accounts as verified by the CA (in Column-B) Note: (for total cost of construction incurred, Minimum of (i) or (ii) is to be considered) Sr. No Particulars Amount (in Rs.) Estimated Incurred & Paid (Column - A) (Column - B) 1 (i) Land Cost: a Acquisition Cost of Land * or Development Rights, lease Premium, lease rent, interest cost incurred or payable on Land Cost and legal cost - - Acquisition Cost of Land to be “Indexed cost of Acquisition” [Circular 2] OR “Prevailing ASR Value” [Circular 11] OR “Market Value of the land/lease charges – as determined by the Government Approved Valuer” Analysis: Circular 2 brought in optional indexation of land, Circular 11 stated that ASR/Jantri Rates or Indexed Cost of land whichever is higher. Now, regulation has also allowed Market Value and left selection of either of the 3 at the option of the promoter. Also, does this mean that either of these 3 options have to be exercised?
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Format No Change FORM 3 (See Regulation 3)
CHARTERED ACCOUNTANTS CERTIFICATE (On Letter Head) (FOR REGISTRATION OF A PROJECT AND SUBSEQUENT WITHDRAWL OF MONEY) Cost of Real Estate Project GujRERA Registration No: PR/GJ/_________________ Project Name Sr. No Particulars Amount (in Rs.) Estimated Incurred & Paid (Column - A) (Column - B) 1 (i) Land Cost: a Acquisition Cost of Land * or Development Rights, lease Premium, lease rent, interest cost incurred or payable on Land Cost and legal cost - - b Amount of Premium payable to obtain development rights, FSI, additional FSI, fungible area and any other incentive under DCR from Local Authority or State Government or any Statutory Authority c Acquisition cost of TDR (if any) d Amounts payable to State Government or competent authority or any other statutory authority of the State or Central Government towards stamp duty, transfer charges, registration fees etc. e Land Premium payable as per annual statement of rates (ASR) for redevelopment of land owned by Public Authorities. f Under Redevelopment / Rehabilitation Scheme: Estimated construction cost of redevelopment / rehab building including site development and infrastructure for the same as certified by Engineer (in Column-A) (ii) Actual Cost of construction of redevelopment / rehab building incurred as per the books of accounts as verified by the CA (in Column-B) Note: (for total cost of construction incurred, Minimum of (i) or (ii) is to be considered) No Change
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FORM 3 Format Option to Tick (Yes) in case of Redevelopment/Rehabilitation Scheme has been made available. The estimated cost of redevelopment entered into here would be reduced from ii a (i) – Estimated Cost of Construction as certified by Engineer. Where redevelopment has been reported in Annexure A, this filed is automatically taken as Yes. The option to provide details in Estimated column is provided one time only and non changeable once submitted. FORM 3 (See Regulation 3) CHARTERED ACCOUNTANTS CERTIFICATE (On Letter Head) (FOR REGISTRATION OF A PROJECT AND SUBSEQUENT WITHDRAWL OF MONEY) Cost of Real Estate Project GujRERA Registration No: PR/GJ/_________________ Project Name Sr. No Particulars Amount (in Rs.) Estimated Incurred & Paid (Column - A) (Column - B) 1 (i) Land Cost: a Acquisition Cost of Land or Development Rights, lease Premium, lease rent, interest cost incurred or payable on Land Cost and legal cost - - b Amount of Premium payable to obtain development rights, FSI, additional FSI, fungible area and any other incentive under DCR from Local Authority or State Government or any Statutory Authority c Acquisition cost of TDR (if any) d Amounts payable to State Government or competent authority or any other statutory authority of the State or Central Government towards stamp duty, transfer charges, registration fees etc. e Land Premium payable as per annual statement of rates (ASR) for redevelopment of land owned by Public Authorities. f Under Redevelopment / Rehabilitation Scheme: Estimated construction cost of redevelopment / rehab building including site development and infrastructure for the same as certified by Engineer (in Column-A) (ii) Actual Cost of construction of redevelopment / rehab building incurred as per the books of accounts as verified by the CA (in Column-B) Note: (for total cost of construction incurred, Minimum of (i) or (ii) is to be considered) Redevelopment Example: Existing Society with 50 units – Additional 50 units are to be built. Cost of construction will be split 50:50 if all units are equal. Cost can be divided on the basis of constructed area or any appropriate method. f Under Redevelopment / Rehabilitation Scheme: (i) Estimated construction cost of redevelopment / rehab building including site development and infrastructure for the same as certified by Engineer (in Column-A) - (ii) Actual Cost of construction of redevelopment / rehab building incurred as per the books of accounts as verified by the CA (in Column-B) Note: (for total cost of construction incurred, Minimum of (i) or (ii) is to be considered) Applicable | Yes/No
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Sub-Total of Development Cost
FORM 3 Format (iii) Cost towards clearance of land of all or any encumbrances including cost of removal of legal/illegal occupants, cost for providing temporary transit accommodation or rent in lieu of Transit Accommodation, overhead cost. - (iv) Cost of ASR linked premium, fees, charges and security deposits or maintenance deposit, or any amount whatsoever payable to any authorities towards and in project of rehabilitation. Sub-Total of Land Cost (ii) Development Cost/Cost of Construction: a (i) Estimated Cost of Construction as certified by Engineer (Column - A) - a (ii) Actual Cost of Construction incurred as per the books of accounts as verified by the CA (Column - B) Note: (for adding to total cost of construction incurred, Minimum of (i) or (ii) is to be considered) a (iii) On-site expenditure for development of entire project excluding cost of construction as per (i) or (ii) above, i.e. salaries, consultants fees, site overheads, development works, cost of services (including water, electricity, sewerage, drainage, layout roads etc.), cost of machineries and equipment including its hire and maintenance costs, consumables etc. All costs directly incurred to complete the construction of the entire phase of the project registered. - b Payment of Taxes, cess, fees, charges, premiums, interest etc. to any Statutory Authority. c Interest payable to financial institutions, scheduled banks, non-banking financial institution (NBFC) or money lenders on construction funding or money borrowed for construction: Sub-Total of Development Cost
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FORM 3 Format 2 Total Estimated Cost of the Real Estate Project (1 (i) + 1 (ii) of Estimated Column –A 100 3 Total Cost Incurred and Paid of the Real Estate Project (1 (i) + 1 (ii) of Incurred Column - B 60 4 Percentage of completion of Construction Work (as per Project Architect’s Certificate on completion of project) N/A 5 Proportion of the Cost incurred on Land Cost and Construction Cost to the Total Estimated Cost.(3/2) 60% 6 Amount which can be withdrawn from the Designated Account Total Estimated Cost *Proportion of cost incurred and paid (Sr. number 2 x Sr. number 5) 7 Less: Amount withdrawn till date of this certificate as per the Books of Accounts and Bank Statement 14 8 Net Amount which can be withdrawn from the Designated Bank Account under this certificate. 46 This certificate is being issued for RERA compliance for the company (Promoter's Name_________) for the project name_________ and is based on the records and documents produced before me and explanations provided to me by the management of the Company; based on the verification of books of accounts till _________. Yours Faithfully, Name Chartered Accountant: For Name of CA Firm: Partner/Proprietor Membership No: COP Date: Place:
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Format Details of Project Loan and Lenders: Lender Name
Amount of Loan taken for Project as per Agreement (INR) Sanctioned Amount Loan Agreement <Attachment> Loan Disbursal Received (INR) Disbursed Amount Mortgage Deed Loan Repaid (INR) Principal Repaid Total Number of Project Units Mortgaged:* Should not be more than units as per Annexure A Balance of Loan (Out Standing) (INR) Principal Outstanding Details of RERA Account: Bank Name Branch Name Account No. Account Name: <Firm Name> RERA Account for <Project Name> Real Estate Project IFSC Code Opening Balance <Closing Balance of last Quarter> Opening Balance Date <Closing Balance Date of Previous Quarter> Deposit during the period Withdrawals during the period Closing Balance Closing Balance Date State
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(ADDITIONAL INFORMATION FOR ONGOING PROJECTS)
1 Estimated Balance Cost to Complete the Real Estate Project (Difference of Total Estimated Project cost less Cost incurred) 40 2 Balance amount of receivables from sold apartments as per Annexure-A to this certificate (as certified by Chartered Accountant as verified from the records And books of Accounts) 10 3 (i) Balance Unsold area to be certified by Management and to be verified by CA from the records and books of accounts 12,000 (ii) Estimated amount of sales proceeds in respect of unsold apartments as per Annexure-A to this certificate. 110 4 Estimated receivables of ongoing project. Sum of (ii) 120 5 Amount to be deposited in Designated Account – 70% or 100% If 4 is greater than 1, then 70% of the balance receivables of Ongoing project will be deposited in designated Account. If 4 is lesser than 1, then 100% of the balance receivables of Ongoing project will be deposited in designated Account. 70% This certificate is being issued for RERA compliance for the company (Promoter's Name_________) for the project name_________ and is based on the records and documents produced before me and explanations provided to me by the management of the Company; based on the verification of books of accounts till (date) _________.
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FORM 3 Format The physical progress of the project as certified by the architect (Form-1) and engineer (Form 2) seems in coherence with actual expenditure incurred & paid considering project specification: Yes No If NO The variation is on account of the following reasons provided by the Promoter of the project. 1. Analysis: Prima Facie or material lack of coherence between Form 1, 2 and Incurred and Paid needs to be reported by CA. The reason for Non-Coherence should be provided by the promoter. Yours Faithfully, Name Chartered Accountant: For Name of CA Firm: Partner/Proprietor Membership No: UDI Number: CA FRN Number: CA Designation: Notes to Certificate: COP Date: Place:
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FORM 3 Format – Annexure A Statement for calculation of Receivables from the Sales of the Ongoing Real Estate Project Booked Inventory Sr. No Block/Type/Bunglow/Category (as per form 1) Flat/Bunglow/Office No/ Plot No Carpet Area (in Sq. Mts.) Area of Exclusive Balcony/Verrandah (sq Mts.) Unit Consideration as per Agreement/Letter of Allotment Received Amount Balance Amount Total - 30 20 10 Total Proposed Total Booked No. of Garages No. of Covered Parking No. of Open Parking (Unbooked Inventory Valuation) Of the Residential/commercial premises Rs.______ per sm. Estimated amount of Sales Proceeds 12000 1000 110 OLD ANNEXURE
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AREA OF EXCLUSIVE BALCONY
FORM 3 Format – Annexure A SAME AS OLD ANNEXURE Heads-> BLOCK TYPE FLAT/BUNGLOW/OFFICE USAGE CARPET AREA AREA OF EXCLUSIVE BALCONY STATUS UNIT AMOUNT RECEIVED Explanation Same as Blocks entered Unit Number Residential/ Shop/ Office/ Others In Sq. M BOOKED/ UNBOOKED INR Amount Editable? No Any time Example A 101 Residential 45.5 2.3 BOOKED 50,00,000 6,00,000
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Format – Annexure A NEW PART OF ANNEXURE Heads-> DATE OF
AGREEMENT OF SALE ENCUMBRANCE STATUS ALLOTTEE NAME TYPE OF KYC KYC UNIQUE ID MOBILE NO OF ALLOTTEE REDEVELOPMENT Understanding Date of Agreement of Sale executed Status of Encumbrance Name of Allottee Standard KYC KYC unique ID Mobile number of allottee in Whether the Unit is being developed under "Redevelopment Rehabilitation" Allowed Values/ Format <DD/MM/YYYY> For BOOKED UNITS ONLY No Encumbrance/ Created/ Released (PAN, AADHAR, DRIVING LICENSE, PASSPORT) PAN Format (<5Alpha><4Digit><1Alpha>), Aadhar Format (<12 Digits>), Driving License Format (<2Alpha><13Digits>), Passport Format (<1Alpha><7Digits>) For BOOKED UNITS ONLY 10 digit Mobile Number YES NO Units must be "BOOKED" only Editable? Any time Example Created ALKA S PATEL AADHAR
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FORM 3 DEFINING ROLES AND DECODING THE FORM
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BREAKING THE Form 3 UP Promoter/Auditor’s Experts Chartered Accountant
RERA BREAKING THE Form 3 UP FORM 3 (See Regulation 3) CHARTERED ACCOUNTANTS CERTIFICATE (On Letter Head) (FOR REGISTRATION OF A PROJECT AND SUBSEQUENT WITHDRAWL OF MONEY) Cost of Real Estate Project GujRERA Registration No: PR/GJ/_________________ Project Name Sr. No Particulars Amount (in Rs.) Estimated Incurred & Paid (Column - A) (Column - B) 1 (i) Land Cost: a Acquisition Cost of Land * or Development Rights, lease Premium, lease rent, interest cost incurred or payable on Land Cost and legal cost - - b Amount of Premium payable to obtain development rights, FSI, additional FSI, fungible area and any other incentive under DCR from Local Authority or State Government or any Statutory Authority c Acquisition cost of TDR (if any) d Amounts payable to State Government or competent authority or any other statutory authority of the State or Central Government towards stamp duty, transfer charges, registration fees etc. e Land Premium payable as per annual statement of rates (ASR) for redevelopment of land owned by Public Authorities. f Under Redevelopment / Rehabilitation Scheme: Estimated construction cost of redevelopment / rehab building including site development and infrastructure for the same as certified by Engineer (in Column-A) (ii) Actual Cost of construction of redevelopment / rehab building incurred as per the books of accounts as verified by the CA (in Column-B) Note: (for total cost of construction incurred, Minimum of (i) or (ii) is to be considered) Promoter/Auditor’s Experts Chartered Accountant
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BREAKING THE Form 3 UP Auto Filled Chartered Accountant 2
Total Estimated Cost of the Real Estate Project (1 (i) + 1 (ii) of Estimated Column –A 100 3 Total Cost Incurred and Paid of the Real Estate Project (1 (i) + 1 (ii) of Incurred Column - B 60 4 Percentage of completion of Construction Work (as per Project Architect’s Certificate on completion of project) N/A 5 Proportion of the Cost incurred on Land Cost and Construction Cost to the Total Estimated Cost.(3/2) 60% 6 Amount which can be withdrawn from the Designated Account Total Estimated Cost *Proportion of cost incurred and paid (Sr. number 2 x Sr. number 5) 7 Less: Amount withdrawn till date of this certificate as per the Books of Accounts and Bank Statement 14 8 Net Amount which can be withdrawn from the Designated Bank Account under this certificate. 46 Auto Filled Chartered Accountant This certificate is being issued for RERA compliance for the company (Promoter's Name_________) for the project name_________ and is based on the records and documents produced before me and explanations provided to me by the management of the Company; based on the verification of books of accounts till _________. Yours Faithfully, Name Chartered Accountant: For Name of CA Firm: Partner/Proprietor Membership No: COP Date: Place:
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BREAKING THE Form 3 UP Chartered Accountant
Details of Project Loan and Lenders: Lender Name Amount of Loan taken for Project as per Agreement (INR) Sanctioned Amount Loan Agreement <Attachment> Loan Disbursal Received (INR) Disbursed Amount Mortgage Deed Loan Repaid (INR) Principal Repaid Total Number of Project Units Mortgaged:* Should not be more than units as per Annexure A Balance of Loan (Out Standing) (INR) Principal Outstanding Details of RERA Account: Bank Name Branch Name Account No. Account Name: <Firm Name> RERA Account for <Project Name> Real Estate Project IFSC Code Opening Balance <Closing Balance of last Quarter> Opening Balance Date <Closing Balance Date of Previous Quarter> Deposit during the period Withdrawals during the period Closing Balance Closing Balance Date State
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(ADDITIONAL INFORMATION FOR ONGOING PROJECTS)
Auto Filled BREAKING THE Form 3 UP (ADDITIONAL INFORMATION FOR ONGOING PROJECTS) 1 Estimated Balance Cost to Complete the Real Estate Project (Difference of Total Estimated Project cost less Cost incurred) 40 2 Balance amount of receivables from sold apartments as per Annexure-A to this certificate (as certified by Chartered Accountant as verified from the records And books of Accounts) 10 3 (i) Balance Unsold area to be certified by Management and to be verified by CA from the records and books of accounts 12,000 (ii) Estimated amount of sales proceeds in respect of unsold apartments as per Annexure-A to this certificate. 110 4 Estimated receivables of ongoing project. Sum of (ii) 120 5 Amount to be deposited in Designated Account – 70% or 100% If 4 is greater than 1, then 70% of the balance receivables of Ongoing project will be deposited in designated Account. If 4 is lesser than 1, then 100% of the balance receivables of Ongoing project will be deposited in designated Account. 70% This certificate is being issued for RERA compliance for the company (Promoter's Name_________) for the project name_________ and is based on the records and documents produced before me and explanations provided to me by the management of the Company; based on the verification of books of accounts till (date) _________.
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BREAKING THE Form 3 UP Chartered Accountant Promoter
The physical progress of the project as certified by the architect (Form-1) and engineer (Form 2) seems in coherence with actual expenditure incurred & paid considering project specification: Yes No If NO The variation is on account of the following reasons provided by the Promoter of the project. 1. Chartered Accountant Yours Faithfully, Name Chartered Accountant: For Name of CA Firm: Partner/Proprietor Membership No: UDI Number: CA FRN Number: CA Designation: Notes to Certificate: COP Date: Place: Promoter
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AREA OF EXCLUSIVE BALCONY
FORM 3 BREAKING THE Form 3A UP Promoter/Auditor’s Experts CA – Verified from A2S/Allotment Letter Heads-> BLOCK TYPE FLAT/BUNGLOW/OFFICE USAGE CARPET AREA AREA OF EXCLUSIVE BALCONY STATUS UNIT AMOUNT RECEIVED Example A 101 Residential 45.5 2.3 BOOKED 50,00,000 6,00,000 CA – Verified from Books of Accounts Heads-> DATE OF AGREEMENT OF SALE ENCUMBRANCE STATUS ALLOTTEE NAME TYPE OF KYC KYC UNIQUE ID MOBILE NO OF ALLOTTEE REDEVELOPMENT Example Created ALKA S PATEL AADHAR NO CA – Verified from A2S CA – Verified from Mortgage Deed CA – Verified from A2S/Allotment Letter and KYC Promoter
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FORM 3 ONLINE FILING AND ESIGNING
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uploading Annexure A Annexure A is the starting point.
FORM 3 uploading Annexure A Annexure A is the starting point. New Template can be downloaded or last uploaded annexure may also be downloaded.
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FORM 3 Summary – Annexure A
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Precautions – Annexure A
FORM 3 Precautions – Annexure A Error in Row number 1 means error in Row 2 of your excel uploaded file Number of units should be same as total units in Commencement Certificate “Amounts received” should tally with the ledger balances of the allottees AFS should be registered where amount received in greater than 10% Mortgaged Units cannot be more than total units of the project Allottee name should be same as in allotment letter/Agreement to Sale In case of joint allotment, KYC, name and mobile number of 1st Allottee is to be added
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Certificate – Land Cost
FORM 3 Certificate – Land Cost
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Certificate – Other Than Redevelopment
FORM 3 Certificate – Other Than Redevelopment
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Certificate – Redevelopment
FORM 3 Certificate – Redevelopment
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FORM 3 CA Certificate
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FORM 3 CA Certificate
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FORM 3 CA Certificate
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FORM 3 CA Certificate
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FORM 3 CA Certificate
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FORM 3 CA Certificate - Loans
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CA Certificate – Bank details
FORM 3 CA Certificate – Bank details
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CA Certificate – Additional Information
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CA Certificate – Coherence
FORM 3 CA Certificate – Coherence
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CA Certificate – Not in Coherence
FORM 3 CA Certificate – Not in Coherence
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CA Certificate – Submission
FORM 3 CA Certificate – Submission
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Preview is not available for Quarterly Return.
FORM 3 Technical Changes Auto Fetching of Bank Account details from project alteration application For Redevelopment – One time data entry in “Estimate Column” shall be allowed There is no option of revision – Hardcopy representations will not be entertained Once CA certificate is E-signed, block submission details, Form 1,2 and 3 and Annexure shall be locked for editing. Preview is not available for Quarterly Return.
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TECHNICAL GUIDE
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Decoding the TECHNICAL Guide
RERA Decoding the TECHNICAL Guide CA Certificate is the last in the sequence of the certificates to be issued for withdrawal of funds. (Chapter 3, Part 1, 2.0) There is no legal requirement that the same CA should issue subsequent certificates for withdrawal from bank (Chapter 3, Part 1, 1.4) The protection under SA-620 (Using the work of an Auditor’s Expert) shall be available only to the extent of “estimate of total project cost”. The CA cannot claim protection for areas of certificate falling under “accounting and auditing”. (Chapter 3, Part 1, 2.1 and 2.2) The ultimate purpose of the Act in adoption of the concept of percentage of completion of work is to protect the interest of the buyers of real estate by ensuring that the promoter gets to withdraw only so much from the amounts collected from allottees, as is commensurate with the progress of work achieved. (Chapter 3, Part 1, 3.4) Land Value: Promoter is allowed to withdraw actual cost or present fair market value of the land, whichever is higher (Chapter 3, Part 1, 4.2.1) Construction and Development Costs: Material, Labour, Cost of Hiring or depreciation on Plant and Machinery, fees for obtaining permissions, design and technical charges, rectification and warranty costs, claims from 3rd parties. (Chapter 3, Part 1, 4.3)
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Decoding the TECHNICAL Guide
RERA Decoding the TECHNICAL Guide Costs not considered as part of construction costs (Chapter 3, Part 1, 6.0) General Administrative cost Selling Costs R&D Costs Depreciation on Idle P&M Costs of unconsumed material delivered at site Advance payment Remuneration/interest on partners capital Word of Caution: Capitalization of interest Note: “In the absence of information about capitalisation of interest as part of cost of assets, the element of interest to be capitalised, if any, has not been considered in the project cost incurred though it is part of the total project cost incurred”
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Decoding the TECHNICAL Guide
RERA Decoding the TECHNICAL Guide Approach for certification (Chapter 3, Part 1, 10.0) Receive from the promoter the necessary particulars of the costs incurred and estimated. Receive certificates issued by the engineer and the architect Reconcile the difference, if any, in the extent of work completed as certified by the engineer and the architect Point out to the promoter the issues emerging from the reconciliation and get the fresh data after corrective action is taken Accept the data as being correct, in the absence of reasons to believe otherwise. Document the analysis of the data and reasons which lent prima facie credibility to the data. Work out the proportion that the project costs incurred up to a particular date bear to the estimated project cost. Express the proportion in terms of percentage
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Decoding the TECHNICAL Guide
RERA Decoding the TECHNICAL Guide Working Papers (Chapter 3, Part 1, 13.0) a letter of engagement stating the nature of certificate required and the purpose for which it will be used the relevant particulars, duly certified by the promoter to be true, received from him regarding the land cost and the cost of construction incurred during the period covered by the certificate as also the particulars to show cumulative land cost and the cost of construction incurred up to the date of the certificate; working showing the manner of attribution of expenditure on interest to the project, that it is in accordance with the applicable AS, if any; the certificates issued by the engineer and the architect; a note on assumptions, if any made while issuing certificate with reasons; a note giving reasons why any evidence is accepted or rejected or why any term or expression is given a particular meaning, etc.
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Project Life Cycle SCENARIOS
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Scenario 1 – Prior to Amendment
FORM 3 Scenario 1 – Prior to Amendment Project Duration – 1.5 years ASR Land Cost – ` 5 crores Construction Cost – ` 15 crores Total Cost – ` 20 crores Expected Revenue – ` 70 crores Since land cost is a small fraction of the total project sales value, amount collected from allottees was blocked in RERA account until BU was received. Quarter Nov-18 Dec-18 Mar-19 Jun-19 Sep-19 Dec-19 Mar-20 Cost 5 10 14 16 20 Sales 7 25 40 70 Withd. Limit 1.5 0.1 (7.5) (14) (54) (29)
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Scenario 1 – After Amendment
FORM 3 Scenario 1 – After Amendment Project Duration – 1.5 years Market Value of Land– ` 35 crores Construction Cost – ` 15 crores Total Cost – ` 50 crores Expected Revenue – ` 70 crores Since market value of land is now considered amount collected from allottees shall not remain blocked in RERA account until BU was received. Quarter Nov-18 Dec-18 Mar-19 Jun-19 Sep-19 Dec-19 Mar-20 Cost 35 40 44 46 50 Sales 5 7 25 70 Withd. Limit 31.5 30.1 22.5 16 (3) 1
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Questions?
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FORM 3 Questions In case unit is cancelled, and the executed AFS has also been cancelled, however, if money received from allottee is yet to be paid back, should it be shown as booked or unbooked inventory? What if the units are being split and sold to different individuals at their request? What should be reported?
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Chartered Accountants
Talati & Talati LLP Chartered Accountants Address: Ambica Chambers, Near Old High Court, Navrangpura, Ahmedabad (M) (O) (E) (W) Thank You
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