Housing Society Audit & Compliance Services
Chartered Accountants
for Mumbai Housing
Societies.
Statutory audit, redevelopment taxation, deemed conveyance, and GST advisory for Managing Committees of mid and large co-operative housing societies registered under the Maharashtra Co-operative Societies Act, 1960.
Four situations where a specialist CA changes the outcome.
Statutory Audit Pending
Form 7-A audit under Section 81 of the MCS Act 1960 has not been filed within three months of the AGM. The Registrar has issued a notice under Section 79, and in continued default may supersede the Managing Committee under Section 78.
We close overdue audits, file Form 7-A with Registrar liaison, and restore the society to good standing.
Redevelopment Ahead
Capital gains treatment of TDR surrender, GST on the builder's PAAA, exposure under Section 56(2)(x) of the Income Tax Act 1961 on the new flat area to existing members, and corpus fund taxability.
We structure the society's tax position before the Development Agreement is signed. Post-signing restructuring is expensive and often impossible.
GST Confusion
Is the ₹7,500 threshold per flat or per member? Is commercial shop rent aggregated? Is GST charged on the excess amount or the full maintenance?
Per CBIC Circular 109/28/2019-GST dated 22 July 2019, GST at 18% applies only on the amount exceeding ₹7,500 per member per month, and only when society turnover exceeds ₹20 lakh. We register, file, and defend.
Deemed Conveyance Blocked
Builder refuses to execute the Conveyance Deed. The society has a statutory right to apply for Deemed Conveyance under Section 11 of the Maharashtra Ownership of Flats Act 1963.
We prepare the complete MahaRERA and Competent Authority file, including CA-certified society financials, share capital record, and member list.
Audit, taxation, advisory — under one engagement.
Statutory Core
Statutory Audit under Section 81 MCS Act 1960
Complete statutory audit and Form 7-A filing with the Commissioner for Co-operation and Registrar of Co-operative Societies. Includes CARO-equivalent reporting on receipts, payments, and fund-wise utilisation.
Internal Audit under Section 81(1)(b)
Mandatory internal audit for societies with paid-up share capital plus reserves exceeding ₹1 crore. Half-yearly review of receipts, payments, bank reconciliation, and internal controls.
Income Tax Return — ITR-5
Annual ITR-5 filing with Section 80P(2)(d) deduction claim on co-operative bank interest. Separate treatment of member income (mutuality) and non-member income (mobile towers, shops, advertisements).
GST Registration & Returns
Registration when applicable, GSTR-1 and GSTR-3B monthly, and GSTR-9 annual return. Correct treatment of the ₹7,500 per member threshold per CBIC Circular 109/28/2019-GST.
TDS Compliance
Deduction, deposit, and reporting under Sections 194C, 194-I, 194J, 194-IA, and 194A. Monthly Challan 281, quarterly Form 26Q, and Form 16A issuance to all vendors.
Advisory
Redevelopment Taxation
TDR and FSI valuation, corpus fund treatment, Section 56(2)(x) exposure on new flat area, GST on PAAA, and Development Agreement review before signing.
Deemed Conveyance
Document assembly, MahaRERA application, Competent Authority proceedings under Section 11 MOFA 1963, and follow-through to order. CA-certified financial schedules.
Bye-Laws 2014 & Section 154B Review
Adoption of Model Bye-Laws 2014, customisation for the society's specific structure, and compliance review against Sections 154B-1 to 154B-32 of the MCS Act 1960.
Support
Managing Committee Training
Structured training on AGM and SGM procedures, Section 75 meetings, resolution drafting, and maintenance of statutory registers under Rule 32 of the MCS Rules 1961.
Notice Management
Written reply and representation for Income Tax scrutiny, GST demand, TDS default, Registrar inspection, and BMC property tax assessment. Same-day acknowledgement.
Mid and large societies choose us because…
Qualified professionals on the team — CAs, article assistants, and compliance managers. Not a one-person practice.
Flats in our largest society client, with commercial shops on the ground floor and multiple wings.
Practising since 2013, serving housing societies across Andheri, Powai, Malad, Goregaon, Chembur, and Ghatkopar.
Co-ordinated handling of Statutory Audit, Income Tax, GST, and TDS under a single engagement letter.
In-person Managing Committee review included for societies above 150 flats. Quarterly for smaller engagements.
Acknowledgement on every Registrar notice, Income Tax intimation, and GST SCN. Written reply within the statutory timeline.
How we begin working with your Managing Committee.
Discovery Call
A 15-minute call with the Chairman, Secretary, or Treasurer. No cost, no obligation, no documents required beforehand.
Scope Note
We review the society's last audit report, bye-laws, and pending notices, and prepare a written scope note within two working days.
Engagement Letter
A formal engagement letter setting out scope, timelines, deliverables, fee, and the partner-in-charge. Signed by both sides before work begins.
Compliance Rhythm
Onboarded to our monthly compliance calendar with statutory-date reminders, document checklists, and scheduled MC review meetings.
Fees are discussed on the Discovery Call after understanding society size, complexity, and the state of pending compliance. We do not publish rate cards because no two societies have identical scope.
Three representative engagements.
Societies anonymised. Outcomes as on file.
Three-year audit pendency resolved; Registrar supersession notice withdrawn.
Situation. The society had not filed Form 7-A for three consecutive financial years. The Deputy Registrar issued a notice under Section 79 and initiated proceedings for supersession of the Managing Committee under Section 78 of the MCS Act 1960.
Outcome. All three years' statutory audits completed and Form 7-A filings submitted within 90 days. Written representation made to the Deputy Registrar. Supersession notice withdrawn.
Redevelopment Agreement restructured pre-signing; potential tax exposure of ₹1.8 crore avoided.
Situation. The builder's proposed Development Agreement exposed existing members to Section 56(2)(x) liability on the difference between the stamp duty value of the new flat and the surrendered area.
Outcome. Agreement renegotiated before signature; corpus treated as reimbursement of hardship. Independent valuation report obtained. Potential member-wise tax liability of approximately ₹1.8 crore avoided.
GST demand of ₹14.2 lakh reduced to ₹2.1 lakh by correct application of CBIC Circular 109/28/2019-GST.
Situation. GST demand raised on the full maintenance amount on the basis that per-member contribution exceeded ₹7,500. Demand of ₹14.2 lakh plus interest and penalty issued.
Outcome. Written submission with case law and CBIC Circular 109/28/2019-GST filed before the Adjudicating Authority, establishing GST applies only on the excess over ₹7,500 per member. Demand reduced to ₹2.1 lakh.
Ten questions Managing Committees ask us first.
By when must a housing society file its statutory audit in Maharashtra?
The audit report in Form 7-A must be filed with the Registrar within three months of the AGM. The AGM must be held on or before 30 September under Section 75 of the MCS Act 1960.
Is Section 80P deduction available to housing societies?
Section 80P(2)(d) allows deduction on interest earned from deposits with co-operative banks. Member maintenance contributions are covered under mutuality. Non-member income (tower rent, shop rent, advertisements) is fully taxable.
When does GST apply on society maintenance?
GST applies when society turnover exceeds ₹20 lakh AND maintenance charged to a member exceeds ₹7,500 per month. Per CBIC Circular 109/28/2019-GST dated 22 July 2019, GST at 18% applies only on the amount exceeding ₹7,500 per member per month — not on the full maintenance amount.
What is Form 7-A?
Form 7-A is the prescribed audit report format under the Maharashtra Co-operative Societies Rules, 1961, filed with the Commissioner for Co-operation and Registrar of Co-operative Societies, Maharashtra State.
Can Managing Committee members be held personally liable?
Yes. Under Section 73 of the MCS Act 1960, Managing Committee members are personally liable for acts of commission or omission causing loss to the society, including breach of statutory duty. This liability survives exit for matters pertaining to one's tenure.
What is deemed conveyance?
A unilateral conveyance of land and building ordered by the Competent Authority under Section 11 of the Maharashtra Ownership of Flats Act 1963, when the builder fails to execute the Conveyance Deed. The society must prepare a complete application file including CA-certified financials.
Is TDS applicable on society payments to vendors?
Yes. Section 194C on contracts above ₹30,000 single or ₹1 lakh aggregate, Section 194J on professional fees above ₹50,000, Section 194-I on rent above ₹2.4 lakh in a year, and Section 194A on interest.
What statutory registers must a society maintain?
Register of Members, Register of Share Capital, Register of Transfers, Register of Nominations, Minutes Book, Audit Register, and Investment Register, under Rule 32 of the MCS Rules 1961 and Bye-Law 127 of the Model Bye-Laws 2014.
How is TDR compensation taxed in society redevelopment?
TDR compensation received by the society is generally treated as a capital receipt. Member-wise distribution of corpus, hardship compensation treatment, and exposure to Section 56(2)(x) on the new flat area require structuring in the Development Agreement before signature.
Does a society need to issue Form 16A?
Yes. Form 16A must be issued quarterly within 15 days from the due date of filing Form 26Q. Non-issuance attracts penalty of ₹100 per day per certificate under Section 272A(2)(g) of the Income Tax Act 1961.
The 2026 Mumbai Society Compliance Calendar.
Every statutory date a 75+ flat Mumbai society Managing Committee needs to track in financial year 2026-27 — AGM, Form 7-A audit, Income Tax, GST, TDS, Professional Tax, Registrar filings.
Download the Calendar →Speak to a CA who audits Mumbai societies every month.
To book a Discovery Call with a partner at Vijay R Singh & Co., use the button below. We will ask for your society name, flats count, services required, and contact details on the call.
A partner will respond within one working day. Details held in confidence.