ICAI Board of Discipline Finds CA Guilty of Professional Misconduct: Solicitation and Improper Audit Acceptance
Overview of the Disciplinary Proceedings
The Board of Discipline of the Institute of Chartered Accountants of India, constituted under Section 21A of the Chartered Accountants Act, 1949, concluded disciplinary proceedings against CA. Vimal Kishore, finding him guilty of professional misconduct under Item (6) and Item (8) of Part I of the First Schedule to the Chartered Accountants Act, 1949. By a formal order dated 19th June 2026, passed under Section 21A(3) of the Chartered Accountants Act, 1949 read with Rule 15(1) of the Chartered Accountants (Procedure of Investigations of Professional and Other Misconduct and Conduct of Cases) Rules, 2007, the Board imposed the penalty of reprimand upon the respondent.
The disciplinary matter was registered under File Nos. PR/38/23/DD/101/2023 (Clubbed PR/39/2023)/BOD/818/2025, PR/40/23-DD/173/2023/BOD/817/2025, and PR/41/2023/DD/174/2023/BOD/832/2025.
Parties to the Proceedings
Complainant: CA. Anurag Sangal
Respondents:
- CA. Vimal Kishore, Partner, M/s Vimal Kishore & Associates LLP
- CA. Kavita Ohri, Partner, M/s Vimal Kishore & Associates LLP
- CA. Nanak Narang, Partner, M/s Vimal Kishore & Associates LLP
**Board of Discipline (Final Hearing – Findings)😗*
- CA. Rajendra Kumar P — Presiding Officer
- Ms. Dolly Chakrabarty — Government Nominee
- CA. Priti Savla — Member
**Board of Discipline (Order on Punishment)😗*
- CA. Babu Abraham Kallivayalil — Presiding Officer (In Person)
- Ms. Dolly Chakrabarty — Government Nominee (In Person)
- CA. Pankaj Shah — Member (Through Video Conference)
Date of Final Hearing: 28th October 2025
Date of Pronouncement of Findings: 8th December 2025
**Date of Order (Punishment)😗* 19th June 2026
Place: ICAI Bhawan, New Delhi
Background and Genesis of the Complaint
CA. Anurag Sangal, the founding partner of the well-established firm M/s Anurag Sangal & Co. (FRN: 00467C), filed a complaint against the three respondents — CA. Kavita Ohri, CA. Vimal Kishore, and CA. Nanak Narang — alleging a series of grave professional transgressions, breach of fiduciary duties, and financial wrongdoing.
Induction into the Complainant Firm
CA. Kavita Ohri and CA. Vimal Kishore had initially joined M/s Anurag Sangal & Co. as employees and article assistants, and were subsequently inducted as partners based on long-standing professional trust and association. In that capacity, they were entrusted with wide-ranging responsibilities, including:
- Management of the firm's bank accounts
- Authority to sign cheques
- Handling client relationships
- Maintenance of books of accounts
- Supervision and hiring of staff
- Overall administrative control of the firm
CA. Nanak Narang had been associated with the complainant firm since 2007 and was actively involved in professional work and client-facing activities.
Covert Formation of a Competing Firm
The complainant alleged that while the respondents were still partners of M/s Anurag Sangal & Co., they surreptitiously and without the complainant's knowledge or consent incorporated a competing firm — M/s Vimal Kishore & Associates LLP — and began soliciting the complainant firm's existing clients to migrate their professional engagements to this newly formed entity. This was allegedly done without obtaining the mandatory No Objection Certificate (NOC) and through misleading communications to clients, including false representations about the reconstitution of the complainant firm.
Financial Irregularities Discovered Post-Exit
Following the departure of the respondents from the complainant firm, a special audit was conducted by an independent firm of Chartered Accountants. The audit report dated 21st December 2022 allegedly uncovered large-scale financial irregularities aggregating to approximately Rs. 55,38 Lakhs, involving:
- Non-work-related payments to relatives and associates of the respondents
- Under-billing of clients
- Unauthorized write-off of receivables
- Diversion of professional fee receipts belonging to the complainant firm
- Unauthorized alteration of agreed remuneration and profit-sharing ratios leading to unjustified fund withdrawals
Alleged Cybercrime
The complaint further alleged that the respondents tampered with the complainant firm's Income Tax e-filing portal credentials, effectively locking the complainant out of the firm's account from October 2022 onwards. This act allegedly disrupted statutory compliance, hampered client servicing, and caused reputational harm to the firm.
Charges Framed Against the Respondents
First Allegation — Solicitation of Professional Work (Item 6, Part I, First Schedule)
It was alleged that the respondent firm solicited the following clients and their professional assignments from the complainant firm through written and personal communication:
- Uttarakhand Sahakari Chini Sangh Ltd.
- Uttarakhand Sahakari Chini Sangh Employees Provident Fund Trust
- John Martyn Memorial Trust
- Welham Boys' School Society
- Welham Boys' School Employees Provident Fund Trust