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Audit & Assurancevia MCA21 Portal (mca.gov.in) — Form CRA-4

CRA-4 — Filing Cost Audit Report with MCA (Within 30 Days of Receiving CRA-3)

Filing Form CRA-4 on MCA21 to submit the cost audit report (CRA-3) received from the CMA to the Central Government within 30 days of receipt — mandatory annual filing under Section 148(6) of the Companies Act, 2013.

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STARTING FROM₹4,999
TYPICAL TIMELINE3 days
DOCS REQUIRED3 documents
APPLICABLE TOCompany

Regulatory Framework

Companies Act, 2013: Section 148(6) — company to submit cost audit report to Central Government within 30 days of receipt from cost auditor; Section 148(7) — company to send cost audit report and response to Central Government query within 30 days. Section 148(8) — penalty for non-compliance: officer in default: fine ₹25,000 to ₹5 lakh + imprisonment up to 1 year. Companies (Cost Records and Audit) Rules, 2014: Rule 6(6) — company to file cost audit report with Central Government in Form CRA-4 within 30 days of receipt of CRA-3; Rule 6(7) — Board to consider cost audit report at Board meeting; Board resolution noting CRA-3 observations and recommendations required. MCA National Cost Data Bank — collects and analyses CRA-4 filings for sector-wide cost benchmarking, particularly for regulated industries.

Overview

Form CRA-4 is the mandatory filing by the company with the Central Government (Ministry of Corporate Affairs) to submit the cost audit report (Form CRA-3) received from the cost auditor (CMA). Under Section 148(6) of the Companies Act, 2013, the company must file CRA-4 within 30 days of receiving the CRA-3 report from the cost auditor.

The 30-day countdown starts from the date on which the company actually receives the CRA-3 from the cost auditor — not from the date the CMA completes the audit. This means companies must track the CRA-3 receipt date carefully (typically evidenced by an acknowledgement letter or email from the CMA), and the CRA-4 filing deadline is calculated from that date.

For a company with an April-March financial year, the typical timeline is: CRA-3 submitted by CMA by 30 September → CRA-4 filed by 31 October.

CRA-4 also requires the company's Board of Directors to consider the cost audit report and pass a resolution noting any recommendations made by the cost auditor. Section 148(7) requires the company to send the cost audit report and any response to the Central Government's queries within 30 days of receipt — treated as part of the CRA-4 compliance.

The CRA-4 form on MCA21 requires: the company's CIN; details of the cost auditor (CMA firm name, ICAI-CMA registration number); the financial year covered; the date CRA-3 was received from the CMA; copy/details of the cost audit report (CRA-3); Board resolution noting the CRA-3; and the digital signature of the MD/WTD or Company Secretary.

The Ministry of Corporate Affairs (MCA) reviews the filed CRA-4 reports through its National Cost Data Bank to identify sector-wide cost trends, under-reporting, and profit manipulation — particularly in price-regulated sectors (drugs, petroleum, telecom, electricity). Companies in regulated sectors receive more scrutiny of their cost audit filings.

How It Works

  1. 1

    CRA-3 Receipt Confirmation & 30-Day Deadline Tracking

    Confirm receipt of CRA-3 from the cost auditor (CMA) — obtain written acknowledgement of the date of receipt (email or letter). Calculate the CRA-4 filing deadline: 30 days from CRA-3 receipt date. Alert the company if CRA-3 has not been received by the expected date (30 September for April-March FY companies) so they can follow up with the CMA.

    Government1 day
  2. 2

    Board Resolution — Noting Cost Audit Report & Recommendations

    Draft the Board of Directors' resolution noting the receipt of the CRA-3 cost audit report and the cost auditor's observations/recommendations. Under Section 148(7), if the cost auditor makes any recommendations, the Board must indicate the action taken or proposed to be taken on each recommendation. This Board resolution is filed along with CRA-4.

    Government1-2 days
  3. 3

    CRA-4 Form Preparation

    Prepare Form CRA-4 with: company CIN, cost auditor's details (CMA firm name + ICAI-CMA registration number), financial year covered, date CRA-3 was received, cost auditor's opinion (clean/qualified), summary of cost auditor's recommendations, and Board's response to recommendations. Attach the CRA-3 report.

    Government1 day
  4. 4

    MCA21 Filing — Digital Signature & Submission

    File CRA-4 on the MCA21 portal with the digital signature of the Managing Director/Whole-Time Director or the Company Secretary. Pay MCA filing fee (₹500 for most companies). Confirm filing acknowledgement SRN (Service Request Number) from MCA21.

    Government1 day
  5. 5

    MCA Acknowledgement & Annual Cost Audit Compliance Closure

    Retain the MCA21 SRN acknowledgement for records. Update the company's compliance register with: CRA-2 filed date, CRA-3 received date, CRA-4 filed date. Commence planning for next year: CRA-2 reappointment filing by 30 September of the next financial year.

    Government1 day

Frequently Asked Questions

What is Form CRA-4 and when is it due?
Form CRA-4 is the mandatory filing by a company with the Ministry of Corporate Affairs (MCA) to submit the cost audit report (Form CRA-3) received from its cost auditor (CMA). Under Section 148(6) of the Companies Act, 2013, CRA-4 must be filed on MCA21 within 30 days of the date on which the company receives CRA-3 from the cost auditor. For companies with an April-March financial year, the CMA must submit CRA-3 by 30 September, which means CRA-4 is typically due by 31 October.
What happens to cost audit reports after they are filed with MCA?
The Ministry of Corporate Affairs maintains a National Cost Data Bank that aggregates cost audit reports filed across companies and sectors. The MCA uses this data for: (i) sector-wide cost benchmarking — particularly for regulated industries like drugs, petroleum, fertilizers, and telecom; (ii) identifying companies where profit margins appear inconsistent with cost structures; (iii) targeted scrutiny of companies in price-regulated sectors where cost data feeds into regulatory price determination; and (iv) comparison of related party transactions at cost vs. market price. Companies in regulated sectors should ensure their cost audit data is accurate and consistent with their statutory financial statements.
Must the Board pass a resolution on the cost audit report?
Yes. Under Rule 6(7) of the Companies (Cost Records and Audit) Rules, 2014, the Board of Directors must consider the cost audit report (CRA-3) at a Board meeting. The Board resolution must note the cost auditor's observations and recommendations and indicate the management's response to each recommendation — either the action taken or proposed. This Board resolution is filed as part of CRA-4. If the cost auditor has made no recommendations or adverse observations, the Board resolution simply notes the receipt of a clean CRA-3 with no adverse observations.
What is the penalty for late CRA-4 filing?
If CRA-4 is not filed within 30 days of receiving CRA-3, the company and every officer in default are liable under Section 148(8) of the Companies Act, 2013 for: a fine of not less than ₹25,000 and up to ₹5 lakh, and/or imprisonment of the officer in default for up to 1 year. Additionally, the company will show as non-compliant for cost audit on MCA21, which may be flagged during annual return scrutiny, statutory audit (CARO remarks), or ROC inspections. There is no late fee mechanism for CRA-4 — unlike annual returns, there is no compoundable penalty that replaces the Section 148(8) criminal liability.
Can the same CMA who prepares the cost records also certify the cost audit report?
No. The cost auditor (CMA who signs CRA-3) must be independent of the company — the same CMA who assists the company with cost records maintenance and cost statement preparation on a retainer basis should not certify the cost audit report, as this compromises audit independence. In practice, companies appoint one CMA or CA firm for cost records maintenance advisory and a separate CMA firm as the statutory cost auditor (who signs CRA-3). This separation is analogous to the separation between internal auditor and statutory auditor.

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