Discrepancies in acquisition and disposal process of

High
immovable properties
Observation:
Discrepancies and lack of controls noted in acquisition and disposal process of immovable properties like:
a) Terms of references (TORs) for acquisition and disposal not defined or complied  
b) Cost benefit/need analysis not performed formally
c) Presentation of facts not accurately done.
d) Job completion report / Technical evaluation not performed.
e) Certain information not available.
Refer annex E for details of transactions and subsequent discrepancies.
Recommendation:
Controls over the acquisition and disposal process should be reassessed and shortcoming should be properly addressed.
 Perceived benefit against Cost incurred should be documented after proper analysis.
 All the facts should be presented accurately to the senior management and the board.
Management Response: Responses awaited.
Responsibility for implementation: CFO

Status as at Dec 2019: Not implemented

Instances noted where due diligence process not followed for acquisition of immoveable property (Land in Peshawar
amounting to Rs. 29.5 million). Refer annex-E for details. Further, checklist/Controls reassessment over the acquisition and
disposal process addressing shortcoming awaited.
Follow-up management response: The guidelines were shared with the IA department. Point to be dropped

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 Annex E:
Discrepancies in acquisition and disposal process of immovable properties

S. No Process Observation

1.     Property Valuer ‘M/S Amir Evaluators and Consultants’ was selected without any approval and SOP
1 Valuation report
compliance.

2.     Sahibzada Anwar Ali (Advocate for legal assessment) and Property agent were selected without
following required procurement due processes (i.e quotation, comparative, approval etc)
Selection of estate broker
2
and advocate/ Lawyer
3.     No agreement made with Property agent.

4.     Patwari charges of 1.2 million (including 1 million setup cost) paid directly to dealer/agent instead of
actual party. Moreover, no supporting documents are available of such charges.

5.     Payment of lawyer fee of Rs. 60,000 is not at proper invoice. Instead, it is on lawyers’ letter head.
3 Payments
6.     Rs. 149,100 on account of WHT on cash withdrawal paid to Seller without any basis.

7.     All ancillary expenses (fees, duties, commission etc.) are paid through cash rather than proper banking
channel.

8.     Lease documents/ lease transfer documents

4 Pending information 9.     Formal need/ cost benefit analysis.

10.   Procurement/management committee and its TORs.

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