Virtual CFO Services

For a private limited company, a Virtual CFO typically oversees compliance with the Companies Act 2013, including maintenance of books of account under Section 128, preparation of financial statements under Section 129, and coordination of the statutory audit under Section 143. On the tax side, the role covers advance tax computation under Sections 207-211 of the Income Tax Act 1961, TDS compliance under Chapter XVII-B, and GST return filing under Sections 37-39 of the CGST Act 2017. The Virtual CFO also monitors compliance calendars for ROC filings (AOC-4, MGT-7A), ensures transfer pricing documentation is in place under Section 92D of the Income Tax Act 1961 for group entities, and prepares MIS reports for the board. This function is legally distinct from a statutory auditor under Section 141 and does not impair auditor independence.

No. Section 141(3)(f) of the Companies Act 2013 disqualifies a person from being appointed as statutory auditor if they, or any partner or employee of the firm, is engaged in the management or administration of the company — which includes the Virtual CFO role. A firm simultaneously providing Virtual CFO services (management advisory, book-keeping, financial controls) and acting as statutory auditor would violate this disqualification. The Institute of Chartered Accountants of India (ICAI) also addresses this conflict under the Code of Ethics (2020 Edition), which prohibits self-review threats that arise when an auditor audits records they have prepared. Our practice maintains a strict separation: Virtual CFO engagements and statutory audit are handled by different engagement teams, and we do not accept audit mandates for Virtual CFO clients.

A startup that is a subsidiary or associate of a foreign entity must comply with Chapter X (Sections 92–92F) of the Income Tax Act 1961 for all 'international transactions' with its associated enterprises — including service fees, reimbursements, loans, and royalty payments. The Virtual CFO ensures that a Transfer Pricing Study (documentation under Section 92D) is prepared by the due date of filing the return (October 31 for companies with international transactions) using the most appropriate method from Rule 10B of the Income Tax Rules 1962 (CUP, RPM, CPM, TNMM, PSM). If the aggregate value of international transactions exceeds ₹1 crore, Form 3CEB (accountant's certificate under Sec 92E, IT Act 1961 (≡ §172, IT Act 2025)) must be filed. The Virtual CFO also tracks the Foreign Liabilities and Assets (FLA) Return required to be filed with RBI under FEMA for any foreign equity or debt received.

Non-listed companies that are Small and Medium-Sized Companies (SMCs) as defined under the Companies (Accounting Standards) Rules 2006 may prepare accounts under the Accounting Standards (AS) framework notified under Section 133 of the Companies Act 2013, rather than full Ind AS. However, companies meeting the thresholds under Rule 4 of the Companies (Indian Accounting Standards) Rules 2015 — paid-up share capital exceeding ₹5 crore or net worth exceeding ₹250 crore or listing status — must mandatorily apply Ind AS. For Ind AS-applicable companies, the Virtual CFO oversees the preparation of financial statements under Ind AS 1 (Presentation of Financial Statements), Ind AS 116 (Leases), and Ind AS 109 (Financial Instruments) among others. The Virtual CFO also coordinates the preparation of the Directors' Report, including the Business Responsibility and Sustainability Report (BRSR) for applicable companies under SEBI LODR Regulations.

A Virtual CFO preparing a company for equity fund-raise ensures that historical financials are restated if necessary under Ind AS, statutory audit is complete and clean, and all ROC filings are current under the Companies Act 2013. For a SEBI-registered investment round or IPO, the Virtual CFO aligns financial disclosures with requirements under the SEBI (Issue of Capital and Disclosure Requirements) Regulations 2018 (ICDR Regulations), including the preparation of restated financial statements for the three preceding years as required under Schedule VI. For private placements under Section 42 of the Companies Act 2013, the CFO ensures that PAS-3 is filed within 15 days of allotment and that the valuation report under Rule 11UA of the Income Tax Rules 1962 is obtained for equity shares. The Virtual CFO also models cap table scenarios and prepares the financial projections investors expect in a data room.