ICAI Board of Discipline Action for Soliciting Clients & Accepting Audits Without Proper NOC

Overview of the Disciplinary Outcome

The Board of Discipline of The Institute of Chartered Accountants of India has held certain members guilty of professional misconduct under Item (6) and Item (8) of Part I of the First Schedule to the Chartered Accountants Act, 1949. The findings and final order culminated in a formal reprimand to CA. Nanak Narang 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 core issues in the matter were:

  • Solicitation of professional work from specific audit clients of another firm, and
  • Acceptance of audit assignments without proper, independent, prior written communication with the previous auditor, as required by the Code of Ethics and Item (8) of Part I of the First Schedule.

The case arose from complaints made by CA. Anurag Sangal, founder partner of M/s Anurag Sangal & Co., against CA. Nanak Narang, CA. Vimal Kishore and CA. Kavita Ohri, who were alleged to have diverted clients and violated ethical norms while still being associated with the complainant’s firm.

Final Order Under Section 21A(3)

Composition of the Board and Order

The final order relating specifically to CA. Nanak Narang was passed in proceedings bearing reference:

  • [PR/41/ 2023/DD/174/2023/ BOD/832/2025]

The Board, constituted under Section 21A of the Chartered Accountants Act, 1949, noted that:

  1. In its findings dated 31st January 2026, the Board had already concluded that Nanak Narang was GUILTY of professional misconduct under Items (6) & (8) of Part I of the First Schedule.
  2. In view of this, disciplinary action under Section 21A(3) was proposed. A communication dated 03rd June 2026 provided an opportunity of personal hearing on 19th June 2026.
  3. On the scheduled date, CA. Nanak Narang appeared in person, confirmed receipt of the findings and made submissions.

After taking into account:

  • The factual matrix,
  • The nature of the misconduct already held proved, and
  • His representation at the hearing,

the Board decided to REPRIMAND CA. Nanak Narang under Section 21A(3).

The order is signed by:

  • Dolly Chakrabarty – Government Nominee
  • CA. Babu Abraham Kallivayalil – Presiding Officer
  • CA. Pankaj Shah – Member

Findings of the Board of Discipline – Background and Core Allegations

Separate but connected proceedings were conducted in three complaint files:

  1. [PR/41/2023/DD/174/2023/BOD/832/2025]
  2. [PR/38/23-DD/101/2023 (Clubbed PR/39/2023)/BOD/818/2025]
  3. [PR/40/23-DD/173/2023/800/817/2025]

The Board of Discipline, sitting at ICAI Bhawan, New Delhi, considered the complaints filed by CA. Anurag Sangal against:

  • CA. Nanak Narang
  • CA. Vimal Kishore
  • CA. Kavita Ohri

All three were, at different points of time, associated with the complainant’s firm and later connected with M/s Vimal Kishore & Associates LLP.

Professional Relationship and Alleged Breach of Trust

  • M/s Anurag Sangal & Co. was described as a long-standing firm with a strong client base and goodwill.

  • CA. Kavita Ohri and CA. Vimal Kishore initially joined the complainant firm as employees/articles, and were later taken as partners. They were given extensive control over:

    • Operation of bank accounts,
    • Signing of cheques,
    • Client relationships,
    • Books of accounts, and
    • Staffing and administration.

  • CA. Nanak Narang had been associated with the complainant firm since 2007 and was also deeply involved in client-related work.

The complainant alleged that, while still part of the complainant firm, the respondents secretly set up a competing entity, M/s Vimal Kishore & Associates LLP, and started diverting professional work and key clients to the new firm.

Alleged Diversion of Clients and Fees

According to the complaint, during FY 2021-22 and earlier periods, the respondents allegedly diverted professional assignments and fee streams away from M/s Anurag Sangal & Co. to the new LLP, including major clients such as:

  • Uttarakhand Sahakari Chini Sangh Ltd.
  • Uttarakhand Sahakari Chini Sangh Employees Provident Fund Trust
  • John Martyn Memorial Trust
  • Welham Boys’ School Society and its EPF Trust
  • JJ Group entities
  • Several educational institutions and charitable trusts

It was alleged that this was done without obtaining proper No Objection Certificates (NOC) from the complainant firm and by misrepresenting the status or constitution of the complainant firm to clients.

Special Audit and Alleged Financial Irregularities

Once the respondents ceased to be associated with the complainant firm, the complainant claimed to have discovered significant irregularities in the books.