# D Somani & Associates > D Somani & Associates is a chartered accountancy firm in Ahmedabad, India, positioned as Risk Advisory & Assurance. Advice before the decision, assurance after it, and key controls monitored on full ERP data every cycle (Continuous Control Monitoring). Six practices: Risk Advisory; Governance & Controls Assurance (internal audit under section 138, IFC, listing readiness); Continuous Control Monitoring; Transaction Assurance (pre-audit before payment, transaction audit after); MIS & Management Consulting; Cross-border Advisory (FEMA and international tax). - Firm: D Somani & Associates, Chartered Accountants (ICAI FRN 157229W) - Founder and proprietor: CA Dheeraj Somani (https://www.linkedin.com/in/dheerajsomani/) - Office: G-3, Avtar Flats, Near Rani Shakti Mandir, Shahibaug, Ahmedabad, Gujarat 380004, India - Contact: info@dsomani.in, +91 7487 919 378 (https://dsomani.in/contact.html) ## Practices - [Risk Advisory](https://dsomani.in/services/risk-advisory.html): A structured look at where the company can lose money, data or its licence to operate, ranked, owned and dated. Risk assessment, SOPs and risk-control matrices, process redesign, fraud, AI and cyber risk. - [Governance & Controls Assurance](https://dsomani.in/services/internal-audit.html): Internal audit under section 138, IFC testing, audit committee support and listing readiness. Planned, risk-based, run on full populations, reported on one page. - [Continuous Control Monitoring](https://dsomani.in/services/ccm-ifc.html): A standing programme that turns your key controls into data tests, runs them on full transaction populations every month or quarter, and brings management a short exception report while the problem is still small. IFC testing falls out of it. - [Transaction Assurance](https://dsomani.in/services/transaction-assurance.html): Pre-audit reviews payments above an agreed value before they are released. Transaction audit tests completed payments on the full population. Together they close the gap that approvals leave open. - [MIS & Management Consulting](https://dsomani.in/services/mis-management-consulting.html): Designing and preparing the monthly pack that promoters run the business on, reconciling it to the books, and advising on what it shows. - [Cross-border Advisory](https://dsomani.in/services/fema.html): FDI, ODI, ECB, LRS, compounding and routine FEMA filings, run alongside international tax so the regulatory answer and the tax answer match. - [International Taxation](https://dsomani.in/services/international-tax.html): Cross-border tax structuring, DTAA analysis, withholding-tax certifications, transfer pricing and taxation of non-residents under the Income-tax Act, 2025. - [GST Health Check](https://dsomani.in/services/gst-health-check.html): Exposure, missed input credits, classification risk and reconciliation gaps, tested on full GSTR and ledger data, in one concise report. - [Statutory & Tax Audit](https://dsomani.in/services/statutory-tax-audit.html): Audit under the Companies Act, 2013 and tax audit under the Income-tax Act, 2025, with a single planning memo, one calendar and a candid management letter. - [Direct & Indirect Tax Compliance](https://dsomani.in/services/tax-compliance.html): Returns, TDS, GST compliance, scrutiny representation and appellate work. Routine filings happen quietly; the partner handles the notices. - [Other Audits & Advisory](https://dsomani.in/services/other.html): Engagements scoped against a specific terms of reference: bank audits, SOP documentation, Company Law and ROC filings, 12A, 80G and FCRA work. ## Instruments (run in the browser) - Section 138 applicability checker: https://dsomani.in/#instruments. Rule 13, Companies (Accounts) Rules, 2014. - LRS TCS calculator: https://dsomani.in/#instruments. Section 394, Income-tax Act, 2025: nil up to Rs 10 lakh, 20% above. ## Notes (articles by CA Dheeraj Somani) - [The MIS is the mirror of the business. Internal audit should audit the mirror.](https://dsomani.in/audit-trail/internal-audit-and-mis-the-mirror.html) (2026-10-06, Governance & Controls): Promoters run the business on the monthly MIS. Internal audit should test whether it is true, use it to pick what to audit, and put control health inside it. - [Buying property abroad under LRS: what is allowed, what it costs, where it gets stuck.](https://dsomani.in/audit-trail/buying-property-abroad-under-lrs.html) (2026-09-29, Cross-border Transactions): Up to USD 2,50,000 a year, no Indian loan, 20% TCS above Rs 10 lakh, and a destination country that may say no. The route, the cost and the reporting. - [Governance and controls assurance: what changes when a company lists.](https://dsomani.in/audit-trail/governance-controls-assurance-listed-companies.html) (2026-09-22, Governance & Controls): Before listing, a control gap is a cost. After listing, it is a disclosure, a certificate, a committee minute and a share price. What changes for pre-IPO, SME-listed and main board companies. - [CCFS-2026 closes on 15 September. What to check before it does.](https://dsomani.in/audit-trail/ccfs-2026-before-15-september.html) (2026-09-08, Companies Act): The window to clear an ROC filing backlog at a tenth of the additional fee shuts on 15 September. What it covers, what it saves, and the control that let the backlog build. - [Vendor risk: beyond the GSTR-2B reconciliation.](https://dsomani.in/audit-trail/vendor-risk-beyond-gstr-2b-reconciliation.html) (2026-09-01, Governance & Controls): The 2B match tells you the vendor exists on the portal. Continuity, compliance, information and integrity risk need their own tests. - [Fraud risk in a digital-payments business: what continuous monitoring catches.](https://dsomani.in/audit-trail/fraud-risk-digital-payments-continuous-monitoring.html) (2026-08-25, Governance & Controls): When money moves in thousands of small transactions a day, sampling fails. The patterns, the population tests, and how to report them. - [Cyber risk for companies that are not in IT.](https://dsomani.in/audit-trail/cyber-risk-for-non-it-companies.html) (2026-08-18, Governance & Controls): A manufacturer is not a technology company. Its bank, ERP and email provider disagree. Eight controls internal audit should test every year. - [Auditing AI: what to ask before the business deploys it.](https://dsomani.in/audit-trail/auditing-ai-before-deployment.html) (2026-08-11, Governance & Controls): AI tools are inside payables, credit and HR already. The questions internal audit should ask before, during and after deployment. - [What audit committees are asking internal auditors in 2026.](https://dsomani.in/audit-trail/audit-committee-questions-internal-audit-2026.html) (2026-08-04, Companies Act): Why the committee changed, where its questions come from in s.177 and the LODR, and the six questions to walk in ready for. - [Building a data-led in-house internal audit team without hiring a data scientist.](https://dsomani.in/audit-trail/in-house-internal-audit-team-data-skills.html) (2026-07-28, Governance & Controls): For CFOs and heads of internal audit: the five skills that matter, how to build them in a team of two to six, and what to stop doing. - [The RBI FCNR "leverage" scheme: why the real number is 14%, not 27%.](https://dsomani.in/audit-trail/rbi-fcnr-leverage-scheme-nri-2026.html) (2026-06-27, International Tax): Influencers say 20 to 27%. Only SBI is live, the real return is about 14% before tax, and US residents keep even less. - [Viksit Gujarat Industrial Policy 2026: a promoter's guide to eligibility and incentives.](https://dsomani.in/audit-trail/viksit-gujarat-industrial-policy-2026-promoter-guide.html) (2026-06-17, Advisory): Who qualifies, how much of your capex comes back, and the decisions to settle before you commit. - [Internal audit in India: a 2026 guide for promoters & audit committees.](https://dsomani.in/audit-trail/internal-audit-in-india-2026-guide.html) (2026-05-26, Governance & Controls): What an internal audit is, why it matters, what a good IA function looks like, and how to brief your auditor. - [Internal audit, reframed.](https://dsomani.in/audit-trail/internal-audit-reframed.html) (2026-05-19, Governance & Controls): Five years that changed how an audit committee should brief its internal auditor. - [IFC testing in India: what design effectiveness actually looks like.](https://dsomani.in/audit-trail/ifc-testing-india-design-effectiveness.html) (2026-05-12, Governance & Controls): A practical note on Internal Financial Controls testing - design vs operating effectiveness, sample sizes, common gaps. - [How to scope an internal audit for a mid-sized manufacturer.](https://dsomani.in/audit-trail/scoping-internal-audit-mid-sized-manufacturer.html) (2026-05-05, Governance & Controls): The risk-universe exercise, calendar planning, data extracts. A real scoping memo, walked through. - [Reports promoters actually read: a structure that works.](https://dsomani.in/audit-trail/reports-promoters-actually-read.html) (2026-04-28, Governance & Controls): Why short reports beat long ones. The one-page executive summary, observation to root cause to recommendation, in a fixed grammar. - [Data analytics in internal audit: replacing sampling with full populations.](https://dsomani.in/audit-trail/data-analytics-internal-audit-full-populations.html) (2026-04-21, Governance & Controls): When and how to run analytics on the full GL, vendor master, employee master. Tooling-agnostic, evidence-led. - [The audit committee calendar: what to ask your IA, when.](https://dsomani.in/audit-trail/audit-committee-calendar-what-to-ask.html) (2026-04-14, Governance & Controls): A 12-month calendar for an audit committee chair. What to expect quarterly, what red flags to push back on. - [Financial due diligence in India: a buyer's and seller's field guide.](https://dsomani.in/audit-trail/financial-due-diligence-india-buyers-sellers-guide.html) (2026-04-07, Financial DD): The full FDD process, from buy-side QoE to sell-side packs to pre-IPO readiness. When you need each, and what to ask for. - [Quality of earnings in a 4-week buy-side review: our approach.](https://dsomani.in/audit-trail/quality-of-earnings-4-week-buy-side.html) (2026-03-31, Financial DD): How we structure a QoE. Adjustments, non-recurring items, pro-forma EBITDA, evidencing. - [Vendor / sell-side due diligence: a primer for first-time sellers.](https://dsomani.in/audit-trail/vendor-sell-side-dd-primer.html) (2026-03-24, Financial DD): Why a vendor DD pack tightens negotiations, what it contains, and how it differs from buy-side. - [Working capital normalisation: how we compute the target.](https://dsomani.in/audit-trail/working-capital-normalisation-how-we-compute.html) (2026-03-17, Financial DD): The 12-month trailing average vs seasonality-adjusted methods, exclusions, deal-doc drafting. - [Net debt and debt-like items: what acquirers add back.](https://dsomani.in/audit-trail/net-debt-debt-like-items-acquirer-checklist.html) (2026-03-10, Financial DD): The deal-stage cheat sheet. What is debt, what is debt-like, what is a provision vs a reserve. - [Red-flag reports: the 5 issues we look for first.](https://dsomani.in/audit-trail/red-flag-reports-five-issues-we-look-for-first.html) (2026-03-03, Financial DD): Revenue cut-off, related-party leakage, capex vs opex, contingent liabilities, working-capital window-dressing. - [ODI filing in India: a practical guide (2026).](https://dsomani.in/audit-trail/odi-filing-india-practical-guide-2026.html) (2026-02-24, Cross-border Transactions): The post-2022 ODI framework: OPI vs ODI, reporting timelines, Form FC, RBI master directions, decoded. - [ECB structuring: the checklist before you raise.](https://dsomani.in/audit-trail/ecb-structuring-checklist-before-you-raise.html) (2026-02-17, Cross-border Transactions): Eligible borrowers, recognised lenders, all-in cost ceiling, hedging, end-use restrictions, conversion to equity. - [FDI in India: which sector caps actually bite in 2026.](https://dsomani.in/audit-trail/fdi-india-sector-caps-that-bite-2026.html) (2026-02-10, Cross-border Transactions): Auto-route vs approval-route by sector, recent press notes, the common reporting traps. - [Compounding under FEMA: how to apply, what to expect.](https://dsomani.in/audit-trail/compounding-under-fema-how-to-apply.html) (2026-02-03, Cross-border Transactions): When compounding is needed, the application, RBI's approach, typical penalties by contravention. - [DTAA application for foreign remittances: a decision tree.](https://dsomani.in/audit-trail/dtaa-decision-tree-foreign-remittances.html) (2026-01-27, International Tax): Step-by-step. When does DTAA apply, MFN clause, beneficial ownership, TRC requirements. - [Transfer pricing under the Income Tax Act, 2025.](https://dsomani.in/audit-trail/transfer-pricing-under-income-tax-act-2025.html) (2026-01-20, International Tax): What's required, benchmarking studies, safe harbour thresholds, ALP issues to watch for. - [Withholding tax on software and SaaS payments: the live issues.](https://dsomani.in/audit-trail/withholding-tax-software-saas-payments.html) (2026-01-13, International Tax): Royalty vs fees-for-technical-services, recent Supreme Court and ITAT positions, practical compliance. - [Taxation of non-residents: NRO, NRE, FCNR demystified.](https://dsomani.in/audit-trail/taxation-of-non-residents-nro-nre-fcnr.html) (2026-01-06, International Tax): What income is taxable in India, repatriation, surcharge and cess, common NRI planning mistakes. - [GST health check: 7 most-missed input tax credits in manufacturing.](https://dsomani.in/audit-trail/gst-health-check-7-most-missed-itc-manufacturing.html) (2025-12-30, GST): The seven ITC categories we keep finding unclaimed in factory-floor companies. Anonymised examples and how to claim. - [Input tax credit on construction services: the open questions.](https://dsomani.in/audit-trail/itc-construction-services-open-questions.html) (2025-12-23, GST): Section 17(5) blocked credits, the Safari Retreats fallout, what's still being litigated. - [E-invoicing in 2026: turnover triggers and practical issues.](https://dsomani.in/audit-trail/e-invoicing-2026-turnover-triggers.html) (2025-12-16, GST): Current thresholds, IRN flow, B2C QR code, common error codes and how to fix them. - [Related-party transactions: documenting audit committee approval.](https://dsomani.in/audit-trail/rpt-documenting-audit-committee-approval.html) (2025-12-09, Companies Act): Section 188, the audit-committee approval matrix, omnibus approvals, disclosure templates that work. - [CSR rules: what changed in 2026.](https://dsomani.in/audit-trail/csr-rules-what-changed-2026.html) (2025-12-02, Companies Act): Latest amendments, computation, unspent CSR account, common reporting errors. ## Other pages - [The firm](https://dsomani.in/firm.html): founder, outcomes, a signature finding. - [Notes index](https://dsomani.in/audit-trail.html) - [Contact](https://dsomani.in/contact.html) - [Privacy](https://dsomani.in/privacy.html) ยท [Disclaimer](https://dsomani.in/disclaimer.html)