Looking a professional advice from practising CA

Hi you can contact Mr. N.B. Aradhya (C.A) contact no. 0821-2444980-Cell-9845285502

Dear Sir / Madam

A spain based private co started in 2009. It got funds for share capital + other expenses including Audit fee from the Spain co (Which is now its 100% holding co). The CA, by a blunder mistake gave a certificate to RBI that the entire amount received was for the shares which were allotted to the Spain co.

Now the problem is that the share value allotted was less than the original amount received. The reason was that it was that CA's fees which he took directly from Spain co's money. This year RBI questioned this under the purview of FDI procedures. Though the amount was not big, this looked as a procedural mistake. That CA too apologised for his carelessness.

If RBI did not accept this transaction as procedurally correct, What should the co do to correct this situation. At that time of commencement, no one except that CA was aware of Indian laws and regulations. They were all foriegners (except that CA). would the company need to pool in the deficit amount again from spain ?

Kindly help me in advising them.