1.   Whether filing of web based Form CSR-2 is required to be filed incase Company had made a voluntary spending in April 2020?

 As per the notification by the Ministry, web based Form CSR-2 shall be filed by Companies falling under the provisions of Section 135(1) of the Companies Act, 2013, whereas as per the help kit, it is referred that web based Form CSR-2 shall also be filed by companies carrying out CSR activities voluntarily. However, it is suggested that we go by the provisions of Section 135

• of the Companies Act, 2013 read with Companies (Accounts) Rules, 2014 and Companies (CSR Policy) Rules, 2014 and not go by the help kit as the voluntary spending is not getting carried forward.

2.   Whether the calculation of Net worth in web based Form CSR-2 is same as Form AOC-4 and Form MGT-7 (Annual Filing)?

Yes. As per the help kit, Net worth should correspond to the amounts mentioned in e-Form AOC-4/AOC- 4 XBRL/AOC-4 NBFC filed for FY 2019-20.

3.   The web based Form CSR-2 to be filed on or before March 31, 2022 is with regard to the CSR obligation for FY 2020-21 (which should have been spent by 31^st March 2021 or 31^st March 2022)?

Since the company is given time to spend the CSR obligation for FY 2022 till 31^st March 2022, the web based Form CSR-2 is for the CSR obligation which should have been spent by 31^st March 2021.

4.   What is the due date for submitting web based Form CSR-2?

The new web based Form CSR-2 for the preceding financial year (2020-21) shall be submitted on or before March 31, 2022. This is in addition to the Form AOC-4 for filing the Company’s financial statement with the Registrar of Companies. These disclosures are also part of the Annual Report on CSR the MCA had mandated Companies to file.

5.   Whether the ‘Average Net Profit’ criteria mentioned under Section 135(5) of the Companies Act, 2013 is Net profit before tax or Net profit after tax?

Computation of Net Profit for Section 135 (5) of the Companies Act, 2013 is as per Section 198 of the Companies Act, 2013 which is primarily PROFIT BEFORE TAX (PBT) with other adjustments as referred in Rule 2(h) of Companies (CSR Policy) Rules, 2014.

6.   Whether web based Form CSR-2 is applicable to a Company that has not completed three years since its incorporation?

If the company has not completed three financial years since its incorporation, but it satisfies any of the criteria mentioned in section 135(1), the CSR provisions including the spending of at least two percent of the average Net Profits made during the immediately preceding financial year(s) are applicable.

7.   What are all the new details required to be submitted vide web based Form CSR-2?

As it is an added reporting compliance on CSR for the Companies, no new details are required to be furnished in web based Form CSR-2.

The form includes:

1. Details of unspent amount pertaining to FY2014-15 to FY2019-20 which has been spent in the financial year, if any;
2. Bifurcation in the calculations of CSR amounts;
3. Bifurcation of details of amount spent against new ongoing CSR project in the financial year;
4. Bifurcation of details of amount spent against new other than ongoing projects in the financial year.

8.   How to generate Project ID in web based Form CSR-2?

1. Once Prescrutiny is successful, click Generate Project ID
2. System generates project ID for each Ongoing Projects mentioned in field 7 of the web based form CSR-2 in below format: FY<Financial year end date>_Sr.No.
3. If Project ID is generated successfully, message is displayed “Project ID is generated ”
4. Check the generated project ID displayed on screen in field 7 of the web based form CSR-2.

9.   How are we going show the composition of CSR committee in the form, whether it is as on 31^st March 2021 or as on present date of filing?

It is required to report the composition of the CSR committee as on 31^st March 2021 and if there is any change in the composition of the CSR committee, then we will add an attachment to the web based form CSR-2 stating the present composition of the CSR committee.