Harun Raaj & AssociatesHarun Raaj & Associates

RERA-CA services · AP & TS · Independent

One recurring RERA-CA engagement for the full project lifecycle

Project registration, designated-account controls, withdrawal certificates, quarterly updates and the annual RERA audit — managed through ONE engagement, with the correct professional signing each document. No coordinating three or four CAs after the deadline has started running. No unresolved self-review conflict when the same records must support both bookkeeping and certification.

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What's inside the engagement

1

Initial project registration

Prepare the project-level filing — estimated cost, completion timeline, promoter particulars, statutory declarations. Organise sanctioned plans, approvals, development documents and title trail for upload.

Cadence: Before advertising, marketing, booking or selling any registrable project. Amendments filed whenever material particulars change.

You provide: Entity records, land and title documents, sanctioned plans, approvals, project budget, construction schedule, promoter details.

Statutory basis: s.3, s.4 and s.11 RERA Act, 2016

2

70% designated-account setup and monthly mapping

Structure the separate designated account per Authority + bank requirements. Map customer collections, land cost, construction cost and permitted expenditure to project-specific ledger heads. First-run receipt-to-bank reconciliation + opening cost schedule; then maintained as part of the monthly close.

Cadence: Setup once at project launch; reconciled monthly thereafter.

You provide: Bank-opening documents, collection data, existing ledgers, customer statements, contractor bills, land-cost records, approved project budget.

Statutory basis: First proviso to s.4(2)(l)(D) RERA Act, 2016

3

Withdrawal-triggered CA certificates

Roll the project-cost schedule forward monthly. Reconcile collections and prior withdrawals. Coordinate the engineer's and architect's certificates. Issue the CA certificate within 48 BUSINESS HOURS of receiving a complete input pack + resolved exceptions (engagement SLA, not a statutory deadline).

Cadence: On demand — monthly or quarterly, driven by cash-flow and bank procedure.

You provide: Current bank statement, customer-receipt register, invoices, payment vouchers, contractor ledgers, updated cost-to-complete, signed engineer + architect inputs.

Statutory basis: Second proviso to s.4(2)(l)(D)

4

Quarterly RERA progress updates

Reconcile the quarter's financial position, collections, sales movement, designated-account activity and reported project cost. Align with architect + engineer physical-progress data. Prepare and file the applicable state return with supporting schedules.

Cadence: Every quarter. TS RERA requires filing within 15 days of quarter-end; AP under current Authority directions.

You provide: Booking + cancellation register, collections, bank statements, project ledgers, approval changes, litigation updates, site-progress data, signed technical certificates.

Statutory basis: s.11(1)(b)–(e), AP RERA Rules 2017, TG RERA Rules 2017

5

Annual RERA audit

Open the annual close BEFORE the 6-month post-FY window becomes a filing problem. Audit project collections, deposits, withdrawals, utilisation, and the relationship between certified completion and funds withdrawn. Exceptions go into a remediation schedule BEFORE the report is signed.

Cadence: Within 6 months of FY end. Where state format requires the statutory auditor's signature, we manage the reconciliation while that auditor signs.

You provide: Final trial balance, project ledgers, all bank statements, customer register, invoices, contracts, prior certificates, quarterly filings, management explanations.

Statutory basis: Third proviso to s.4(2)(l)(D); AP RERA bank circular; TG RERA Form 7

6

Cross-tax and corporate touchpoints, coordinated

Sequence the RERA close with tax audit (s.44AB, Form 3CD), GST returns + GSTR-9/9C, TDS on salaries + contractors + rent, and MCA filings. Purpose: preserve a documented reconciliation between them — not force one format into another.

Cadence: Statutory cadences (monthly / quarterly / annual) synchronised on one calendar.

You provide: GST data, TDS workings, payroll records, vendor master, contracts, purchase + sales registers, general ledger, previous statutory filings.

Statutory basis: s.44AB Income-tax Act; CGST Act framework; applicable MCA provisions

Why not just use your compliance CA?

The independence question — stated correctly

s.4(2)(l)(D) requires the withdrawal certificate to be issued by a CA in practice. It does NOT contain a blanket rule that the CA maintaining your books can never issue a RERA certificate. The practical issue is the self-review threat: a CA should not certify project-cost allocation, utilisation and withdrawal proportion without assessing whether prior involvement in preparing the underlying records compromises independence. We perform that conflict check before accepting the certification role and allocate signatories accordingly. Current AP RERA and TG RERA formats also contemplate the statutory auditor signing the annual report — a state-specific position that we respect.

The RERA return is not an income-tax return

RERA reporting follows project-level collections, designated-account movements, eligible project expenditure and completion-linked withdrawal. Income-tax reporting follows the assessee's books and the classifications required under the tax law. Totals may be connected, but the formats and purposes are different — signing both without a reconciliation trail produces contradictions in land cost, construction cost, customer advances, revenue recognition and related-party balances. Those contradictions become visible the moment the Authority, lender, allottee or tax auditor compares the records.

Withdrawal work runs on a transaction SLA

A withdrawal certificate is needed when the project requires access to the designated funds — not on a routine month-end visit. Our service target is 48 business hours after receipt of a complete, internally consistent input pack. Missing invoices, unsigned technical certificates and unresolved bank differences pause the SLA until the exception is cleared.

Sequence of engagement

  1. Initial project audit. Review registration, approved cost, disclosures, designated-account structure, certificates already issued, quarterly filings, unresolved Authority communications.
  2. 90-day compliance catch-up plan. Findings converted into a dated action plan: overdue filings, missing records, bank corrections, cost reclassifications, professional certificates and management decisions.
  3. Month-one baseline reconciliation. Establish the opening project position — collections, deposits, withdrawals, eligible cost, completion data, differences between RERA schedules and books.
  4. First quarterly return + first withdrawal certificate. Run the recurring process once from source documents to filed / signed output. This establishes the data cut-off, review responsibilities and 48-business-hour workflow.
  5. Year-one audit. Reconcile the quarterly record to the FY books and prepare the annual RERA audit within the 6-month window. Statutory auditor signs where state format requires.

What we do NOT do

Architect or engineer certification

The architect and engineer certify matters within their respective professional scope. We coordinate their figures with the financial schedules but sign only the CA certificate under s.4(2)(l)(D).

Physical inspection or quantity surveying

We do not certify physical completion from a site inspection. Measurement, valuation or physical verification stays with the appropriate architect, engineer or independent surveyor.

Legal drafting

We do not draft agreements for sale, title opinions, development agreements or allottee-consent documents. Your advocate prepares and approves them — we provide the financial schedules and project data required. Material alterations under s.14 remain a legal process managed by your advocate.

Frequently asked questions

Can you take over a project that is already halfway through?

Yes, subject to an initial project audit and satisfactory records. We reconstruct the position from registration through the current date. If the opening position cannot be supported, we first issue an exception list and 90-day catch-up plan — we do not certify an unsupported brought-forward figure because it appeared in an earlier return.

What if you work with multiple builders in the same market?

Each engagement begins with a conflict and independence review. Project data is maintained separately, access is restricted to the assigned team, and information is not shared between promoters. We decline or restructure an assignment where professional independence, confidentiality or an existing appointment creates an unacceptable conflict.

Do you handle projects across Andhra Pradesh and Telangana?

Yes. The central obligations arise under the RERA Act; forms, portal procedures and quarterly requirements differ by state. AP projects follow the AP RERA Rules 2017 and current Authority directions; TS projects follow TG RERA forms and the QPR circular.

How do you transition when we already have a compliance CA?

We do not require an unnecessary replacement. We agree a responsibility matrix covering bookkeeping, GST, TDS, income tax, MCA, withdrawal certification, quarterly RERA reporting and the annual RERA audit. Your existing CA provides ledgers and closing schedules; we return reconciliation differences in a structured query sheet. Where the state format requires the statutory auditor's signature, that appointment is respected.

What happens if a withdrawal is delayed because the certificate is late?

The 48-business-hour SLA starts only after a complete, internally consistent input pack + signed technical certificates + responses to material exceptions are received. If delay occurs within our controlled review process, the matter is escalated immediately and the revised delivery time is documented. Any commercial remedy is stated in the signed engagement letter — not implied by this page. No CA can guarantee bank/Authority acceptance where the underlying documents or bank procedure is defective.

Do you also handle the income-tax audit?

Yes, where the appointment is professionally permissible and s.44AB applies. Scope is agreed separately but run on the same closing calendar so the tax-audit particulars and RERA schedules have a documented reconciliation.

Do you conduct a "GST audit"?

There is no separate CA-certified GST audit merely because the builder is registered. We handle the applicable periodic returns and coordinate the annual return + GSTR-9C reconciliation where required. Scope confirmed from the promoter's registration status, turnover, project structure and the provisions applicable for that year.

Can you issue only one urgent withdrawal certificate?

Only after reviewing the project's registration, cumulative cost, prior withdrawals and designated-account trail. A withdrawal certificate is cumulative assurance — not a signature on the current month's payment list. Where records are complete, the assignment may begin with an urgent certificate and then move into the recurring engagement.

Book a project review

A 90-minute working session for one registered or proposed project.

Before the meeting, you share the registration record, latest RERA filings, designated-account statements, current cost sheet and certificates already issued. During the session, we examine:

  • Registration and disclosure status
  • Designated-account structure and reconciliation
  • Withdrawal eligibility and certificate trail
  • Quarterly-return status
  • Annual-audit readiness
  • Differences between the RERA schedules, books, GST records and tax reporting

After the session, you receive a written compliance-catch-up plan identifying open items, responsible person, document required and recommended sequence.

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