Manager - Finance & Accounts
58384 Points
Joined June 2010
Hi Komal,
Thanks for explaining your situation — this is a sensitive compliance issue with ICAI, and here's how it typically works along with what you can and cannot do now.
๐ Your Situation Recap:
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You started articleship in Pune
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You relocated in May 2023 and continued training in another firm (presumably in your hometown)
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You did not apply for a transfer at that time (May 2023)
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You continued articleship until Oct 2023, but ICAI has no record of the transfer or continuation
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You have not yet filed Form 108 (Completion)
๐ซ ICAI’s Position on Backdated Transfer:
ICAI does not allow backdated transfer or records without proper filing at the time of change. As per ICAI norms:
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Form 109 must be filed at the time of transfer (with valid reasons, especially after the 1st year)
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Form 102 & 103 (for re-registration) should be submitted for the new firm
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ICAI does not accept retrospective filings unless there is strong justification (e.g., medical, natural calamity, etc.)
โ
What You Can Do Now:
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Contact Your Regional ICAI Office (Western Region, for Pune)
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Go in person if possible or write an email with full details
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Explain your case honestly and request for condonation of delay in filing
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You will likely be asked to submit:
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A letter explaining the delay
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Articleship completion letter from both old and new principal (if applicable)
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A condonation request letter
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Late fee & penalty, if applicable
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Supporting documents (address proof, email trails, medical records if any)
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Principal’s Cooperation is Key
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Both your previous and new principal should be willing to sign forms and support the transition
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If either refuses, it complicates the matter significantly
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Don’t File Form 108 Yet
๐งพ Documents You May Need:
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Request letter for condonation
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Affidavit (in some cases)
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Supporting documents (e.g., relocation reason)
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Forms 109, 103, 108 (after acceptance)
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Fees for condonation/late submission
๐ ICAI Contact – WIRC (Pune comes under WIRC):
๐ Important:
Do not attempt to file backdated forms on the portal without ICAI approval — it may lead to your articleship period being invalidated or delayed, affecting CA Final eligibility.