The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) SOUTH ASIA | Bangladesh | Governance Global Practice | Requesting Unit: SACBD | Responsible Unit: ESAG2 IBRD/IDA | Program-for-Results Financing | FY 2014 | Team Leader(s): Winston Percy Onipede Cole, Syed Khaled Ahsan Seq No: 13 | ARCHIVED on 25-Jun-2020 | ISR42143 | Created by: Syed Khaled Ahsan on 03-Jun-2020 | Modified by: Syed Khaled Ahsan on 18- Jun-2020 Program Development Objectives Program Development Objective (from Program Appraisal Document) The PDO is to improve revenue mobilization and transparency in the VAT administration. Overall Ratings Name Previous Rating Current Rating Progress towards achievement of PDO Moderately Satisfactory Moderately Satisfactory Overall Implementation Progress (IP) Moderately Satisfactory Moderately Satisfactory Implementation Status and Key Decisions Project Status and Key Issues: The COVID-19 situation in Bangladesh led to a shutdown across many public offices from March 26 to May 30, 2020. It has disrupted the operations of the VAT Improvement Program (VIP). Hence, the closing date of the VIP has been extended until December 2020 based on the request of the National Board of the Revenue (NBR). This would enable the VIP to complete the remaining activities by the closure of the program. The Bank advised for a revised implementation and program expenditure plan by the VIP. They were also reviewed during the mission meeting on May 13, 29020. Special attention is needed to effectively conduct user acceptance test (UAT) for different business processes. The VIP is advised to conduct training on knowledge transfer remotely in this pandemic situation. It is important that the core staff are retained in the VIP to ensure that the results are full achievement by the end of the program. Data on Financial Performance Disbursements (by loan) Project Loan/Credit/TF Status Currency Original Revised Cancelled Disbursed Undisbursed % Disbursed P129770 IDA-54260 Effective USD 60.00 60.00 0.00 40.02 13.67 75% Key Dates (by loan) Project Loan/Credit/TF Status Approval Date Signing Date Effectiveness Date Orig. Closing Date Rev. Closing Date P129770 IDA-54260 Effective 09-May-2014 07-Dec-2014 11-Jan-2015 30-Jun-2020 31-Dec-2020 6/25/2020 Page 1 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) DLI Disbursement Achievement Disbursed amount in Disbursement % for DLI ID DLI Type Description Coc DLI Amount Status Coc DLI Loan: IDA54260-001 005 Regular DLI#1: DLR 1.2.1 XDR 3,250,000.00 Fully Achieved 3,250,000.00 100 % Partially 006 Regular DLI#1: DLR 1.2.2 XDR 5,760,000.00 4,820,000.00 84 % Achieved Partially 007 Regular DLI#1: DLR 1.2.3 XDR 4,480,000.00 1,584,576.00 35 % Achieved 008 Regular DLI#1: DLR 1.2.4 XDR 4,480,000.00 Not Achieved 0.00 Partially 009 Regular DLI#2: DLR 2.1 XDR 960,000.00 960,000.00 100 % Achieved Partially 010 Regular DLI#2: DLR 2.2 XDR 960,000.00 960,000.00 100 % Achieved 011 Regular DLI#3: DLR 3.1 XDR 1,600,000.00 Not Achieved 0.00 012 Regular DLI#3: DLR 3.2 XDR 1,600,000.00 Not Achieved 0.00 016 Regular DLI#6: DLR 6.1 XDR 650,000.00 Fully Achieved 650,000.00 100 % 017 Regular DLI#6: DLR 6.2 XDR 650,000.00 Fully Achieved 650,000.00 100 % 018 Regular DLI#6: DLR 6.3 XDR 650,000.00 Fully Achieved 650,000.00 100 % PPF Refinancing of Preparation 019 -- 23,070.00 -- 23,068.53 100 % Refinancing Advance 020 Regular DLI#1: DLR 1.2.5 XDR 4,480,000.00 Not Achieved 0.00 021 Regular DLI#2: DLR 2.3 XDR 1,600,000.00 Fully Achieved 1,600,000.00 100 % 022 Regular DLI#2: DLR 2.4 XDR 1,600,000.00 Not Achieved 0.00 023 Regular DLI#3: DLR 3.3 XDR 1,600,000.00 Not Achieved 0.00 Partially 024 Regular DLI#6: DLR 6.4 XDR 650,000.00 433,355.00 67 % Achieved Partially 025 Regular DLI#6: DLR 6.5 XDR 666,930.00 444,620.00 67 % Achieved Partially 5.2 Regular DLI#5 DLR 5.2 XDR 960,000.00 960,000.00 100 % Achieved Partially 5.3 Regular DLI#5: DLR 5.3 XDR 960,000.00 960,000.00 100 % Achieved 5.1 Regular DLI# 5: DLR 5.3 XDR 1,220,000.00 Fully Achieved 1,220,000.00 100 % Program Action Plan 6/25/2020 Page 2 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) 1.By no later than June 30, 2016,the Recipient shall establish Active Registered Baseline ref. to in DLR#2.1, On-line Action Description Filing Baseline ref. to in DLR#3.1 and LTU Baseline ref. to in DLR#4.1 of the table set forth in Sec. IV.A.2 of Schedule 2 to FA. Source DLI# Responsibility Timing Timing Value Status Technical Client Recurrent Yearly Completed Completion Measurement By no later than June 30, 2016 Baseline established at 94,910 for Active VAT Taxpayers. Of the 134 registered Large Taxpayer Units (LTUs), 44% Comments have submitted their returns for February 2020 online. 2a. The Recipient shall carry out, under terms of reference acceptable to the Association, the following independent Action Description taxpayer satisfaction surveys- 2014 survey by no later than June 30, 2015. Later agreed with GoB to comply with it by June 30, 2016. Source DLI# Responsibility Timing Timing Value Status Technical Client Due Date 30-Jun-2015 Completed Completion Measurement Final survey report published on NBR website - http://nbr.gov.bd/uploads/public-notice/NBR_2017_PDF.pdf Comments Final survey report published on NBR website - http://nbr.gov.bd/uploads/public-notice/NBR_2017_PDF.pdf 2b. The Recipient shall carry out, under terms of reference acceptable to the Association, the following independent Action Description taxpayer satisfaction surveys- 2016 survey by no later than June 30, 2017. Source DLI# Responsibility Timing Timing Value Status Technical Client Due Date 15-Feb-2019 Completed Completion Measurement Final survey report published on NBR website - http://nbr.gov.bd/uploads/public-notice/NBR_2017_PDF.pdf Comments Final survey report published on NBR website - http://nbr.gov.bd/uploads/public-notice/NBR_2017_PDF.pdf 2c. The Recipient shall carry out, under terms of reference acceptable to the Association, the following independent Action Description taxpayer satisfaction surveys- 2018 survey by no later than October 30, 2020. Source DLI# Responsibility Timing Timing Value Status Technical Client Due Date 31-Dec-2020 Not Yet Due Completion Measurement Survey report available. Comments Selection of firm for 2nd Taxpayer Satisfaction Survey initiated in May 2020. 3.By no later than 12 mnths after Effective Date, Recipient shall install, & maintain throughout imple., a fixed asset Action Description tracking system in VAT Wing to record, track & manage assets procured under VIP, incl. prov. of trng. to staff.Due date: Sep30,2020 Source DLI# Responsibility Timing Timing Value Status 6/25/2020 Page 3 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) Fiduciary Systems Client Recurrent Yearly In Progress Completion Measurement completed Fixed Asset Software that was previously installed is no longer in use. VIP will re-implement a Fixed Asset Tracking Comments System and start producing periodic Fixed Asset Report by July 2020. 4.By no later than 1 month after the Effective Date, Recipient shall form and maintain throughout implementation of Action Description the Program, a 7-member team evaluation committee, under ToR acceptable to the Association, responsible for high value IT procurement Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems Client Due Date 30-Oct-2014 Completed Completion Measurement Completed Comments Done. 5.By no later than 6 months after the Effective Date, Recipient shall report and thereafter continue reporting Action Description throughout implementation of Program, on key procurement indicators agreed with the Association using Recipient’s proc. monitoring systems Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems Client Due Date 30-Mar-2015 Completed Completion Measurement Completed Comments Done. 6a. By no later than 3 months after the Effective Date, Recipient shall appoint under ToR acceptable to the Action Description Association and maintain throughout imp. of the Program, a focal point within ERD. Source DLI# Responsibility Timing Timing Value Status Technical Client Recurrent Continuous Completed Completion Measurement Completed Comments Done. 6bi.By no later than 3months after Effective Date,Recipient shall start collecting and compiling into formats agreed Action Description with Association, and thereafter continue collecting throughout implementation of the Prog., all Prog fraud and corruption complaint Source DLI# Responsibility Timing Timing Value Status Client Recurrent Semi-Annually In Progress Completion Measurement 6/25/2020 Page 4 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) Comments 6bii. By no later than 3 months after the Effective Date, Recipient shall submit, throughout implementation of the Action Description Program, the aforementioned reports to the Association on a semi-annual basis. Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems Client Recurrent Semi-Annually Completed Completion Measurement Reports submitted The Anti-Corruption Commission (ACC) as the primary anti-corruption agency in Bangladesh has been consistently Comments submitting sem-annual reports. Action Description 7a. By no later than September 30, 2020, the Recipient shall carry out training on e-waste handling to IT NBR staff. Source DLI# Responsibility Timing Timing Value Status Technical Client Due Date 30-Sep-2020 Revised Date Completion Measurement Completed Comments The VIP PIU is planning training for NBR officials on e-wastage handling. 7b.By no later than June 30, 2015, Recipient shall start, and thereafter maintain throughout implementation of the Action Description Prog., proper record keeping of equipment purchase, reused and auctioned. Source DLI# Responsibility Timing Timing Value Status Fiduciary Systems Client Recurrent Continuous In Progress Completion Measurement Records maintained Comments VIP will re-implement a Fixed Asset Tracking System and start producing periodic Fixed Asset Report by July 2020. 8. By June 30, 2015, Recipient shall set up NBR’s contact center, under terms of reference acceptable to the Action Description Association Source DLI# Responsibility Timing Timing Value Status Technical Client Due Date 30-Jun-2015 Completed Completion Measurement Contact center set up Comments Done. Risks 6/25/2020 Page 5 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) Systematic Operations Risk-rating Tool Risk Category Rating at Approval Previous Rating Current Rating Political and Governance -- Substantial Substantial Macroeconomic -- Substantial Substantial Sector Strategies and Policies -- Substantial Substantial Technical Design of Project or Program -- Substantial Substantial Institutional Capacity for Implementation and -- Substantial Substantial Sustainability Fiduciary -- Substantial Substantial Environment and Social -- Low Low Stakeholders -- Substantial Substantial Other -- -- -- Overall -- Substantial Substantial Results PDO Indicators by Objectives / Outcomes Increase in VAT revenues (Numbers in Thousands) IN00853575 ►Increase in VAT revenues (Number (Thousand), Custom) Baseline Actual (Previous) Actual (Current) End Target Value 686,800,000.00 9,258,114.00 1,265,708,300.00 914,100,000.00 Date 30-Jun-2017 08-Jun-2019 13-May-2020 30-Jun-2020 Number in Billion Taka. http://nbr.gov.bd/uploads/publications/IMG_20190805_00081.pdf Comments http://nbr.gov.bd/uploads/publications/2016-17_Vat_Saroni.pdf Greater transparency of the tax administration IN00853581 ►Greater transparency of the tax administration (Text, Custom) Baseline Actual (Previous) Actual (Current) End Target VAT Law 2012 and by- laws published, regulations and interpretations Baseline Non-existent Refunds not disclosed published, system set- Value -- on monthly basis. up to account VAT collection, monthly VAT data published, VAT satisfaction survey published, VAT 6/25/2020 Page 6 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) appeals resolved in six months. Date 30-Jun-2013 31-Dec-2019 13-May-2020 30-Jun-2020 A total 159,498 taxpayers have been registered online as of May 8, 2020. NBR releases monthly VAT collection data on their website but not on refunds, and they are not being Comments published it regularly/ by months.. Intermediate Results Indicators by Results Areas Increased VAT revenues IN00853584 ►IR Indicator 1.1: VAT Implementation Plan on Track (Text, Custom) Baseline Actual (Previous) Actual (Current) End Target 75% complete - Registration and Return modules completed and VAT Registration module UAT undertaken. Consultant has signed a implementation (75% contract providing the complete) .As at May 6, A total 159,498 VAT Audit System set- Value NBR with Program 2019, there are 167,342 taxpayers have been up management services. VAT registered online as of May 8, 2020 Target is not fully achieved. Date 01-Jul-2013 07-May-2019 13-May-2020 30-Jun-2020 Some functionalities of the registration systems are yet to be fully configured. Comments IN00853586 ►IR Indicator 1.2: Number active VAT Taxpayers (in 000) (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 94,910.00 118,317.00 159,458.00 120,000.00 Date 01-Jul-2016 31-Dec-2019 13-May-2020 30-Jun-2020 Active VAT Taxpayers is 159, 498 as of May 8, 2020, up from a baseline of 94,910 verified during the fifth Comments mission in May 2019. IN00853588 ►IR Indicator 1.3: Percentage of large taxpayers submitting on-line returns and VAR payments (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 0.00 44.00 90.00 Date 01-Jul-2016 31-Dec-2019 13-May-2020 30-Jun-2020 Some 44% of the Large Taxpayer Units (LTUs) have submitted their returns for February 2020 online. Another 42% have saved their online returns in draft format but are unable to submit due to some technical Comments problems. The percentage will easily exceed the target of 90% by December 2020. The e-payment of taxes by LTUs will be made available after normal business resumes. IN00853589 6/25/2020 Page 7 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) ►IR Indicator 1.4: Value of VAT e-payments (Number (Thousand), Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 0.00 0.00 105,000,000.00 Date 29-Jun-2018 31-Dec-2019 13-May-2020 30-Jun-2020 The VAT Collection System is only 26.33% complete. VIP had planned to implement e-payments in April 2020 but delayed due to COVID-19. E-payment system has been tested successfully with Bangladesh Bank, HSBC and Midland Bank. VIP plans to implement the e-payment gradually with 100 taxpayers using Comments HSBC and Midland Bank. Based on the success of the pilot, the system will be opened for other taxpayers. This will be executed step-by-step from July 2020 according to the revised implementation plan. IN00853590 ►IR Indicator 1.5: Number of VAT stop filers (Number, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 99,999.00 99,999.00 999,999.00 77,777.00 Date 29-Jun-2018 31-Dec-2019 13-May-2020 30-Jun-2020 Number of stop filers has been reducing each month with the increase in online returns submission since the inauguration in October 2019. However, the VIP could not give any specific number of stop filers as of May 2020. The number of online return submission was 33,496 in February 2020; 28,978 in March 2020 Comments and 32,228 in April 2020. Value put for Actual, Baseline and End Target will be fixed in due course. IN00853591 ►IR Indicator 1.6: Average time to process and issue tax refunds (Days, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 120.00 120.00 120.00 102.00 Date 29-Jun-2018 31-Dec-2019 13-May-2020 30-Jun-2020 The Refund Module is at development stage. A Government Order (GO) has been issued to Commissionerates on how to handle refunds and to settle undisputed refunds quickly, especially as taxpayers need cash during the COVID-19 situation. Letter has been sent to all Commissionerates to collect Comments information on average time it currently takes to process refunds in the absence of the refund module in the IVAS. Values for Actual, Baseline and End Target will be fixed in due course. IN00853592 ►IR Indicator 1.7: Percent of audits per year resulting in additional tax assessments (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 20.00 20.00 20.00 25.00 Date 23-Dec-2018 31-Dec-2019 13-May-2020 30-Jun-2020 The Audit Module is under development stage. Therefore, the percentage of audits resulting in additional tax assessments could not be determined because section 19 sub-section 2 of the new VAT Act 2012 requires a VAT manual to carry out any VAT audit. The draft Audit Manual sent by WB Team is under Comments review by NBR. WB will submit the translated version to Bangla by June 2020. Values for Actual, Baseline and End Target will be fixed in due course. 6/25/2020 Page 8 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) Greater transparency IN00853585 ►IR Indicator 2.1: Fiduciary Action (Text, Custom) Baseline Actual (Previous) Actual (Current) End Target At least 50% of the Program’s competitive Quarterly Fund Utilization bidding contracts granted Report are submitted by during the First Fiscal the Program to the Quarterly Fund Year has been carried out Internal Resources 75 percent of NCB Utilization Report are through electronic Division (Finance contracts are done submitted by the government procurement Division). 100% of the through e-GP. Program to the Internal (e-GP); During the First goods procurement were All significant audit Resources Division Fiscal Year a fund completed through e-GP. objections resolved in (Finance Division). Value utilization report has been As on the date of 6 months. 100% of the goods submitted by the NBR to Deloitte’s field visit in Submit quarterly fund procurement were the Finance Division on a December 2019, a utilization report to FD completed through e- quarterly basis; Audit significant audit objection & complete fund GP. The are 11 out of observations considered (Para 2) was unresolved release processes 23 outstanding audit to significant have been for more than a year from after each quarter. be resolved. resolved in a satisfactory the date of receipt of manner within 6 months audit objections from from the reception of the FAPAD. annual reports. Date 30-Jun-2015 31-Dec-2019 13-May-2020 30-Jun-2020 Quarterly Fund Utilization Report are submitted by the Program to the Internal Resources Division (Finance Division). 100% of the goods procurement were completed through e-GP. In the Procurement Plan of FY 2018- 2019, a total 43 contract packages of Goods, Works, Services and Non Consulting Services were listed for procurement in FY 2018-2019 using different procurement method of which 27 were planned to be followed National Competitive Bidding (NCB)/Open Tendering Method (OTM) of procurement.  Out of 43 packages 15 Goods, 19 consulting services, 5 non-consulting services and 4 were works.  Out of 15 of Goods category 8 were planned to follow National Competitive Bidding (NCB)/Open Tendering Method (OTM) of procurement. Comments  Out of 18 Service category, 12 were planned to follow QCBS, 3 Single Source Selection (SSS), and 3 Individual Consultants (SIC).  Out of 4 Works category, all were planned to follow Request for Quotation (RFQ) method of procurement.  Out of 5 Non-Consulting Services category, all were planned to follow National Competitive Bidding (NCB)/Open Tendering Method (OTM) of procurement. “All significant audit observations resolved in 6 months”. As on the date of Deloitte’s field visit in December 2019, a significant audit objection (Para 2) was unresolved for more than a year from the date of receipt of audit objections from FAPAD. IN00853587 ►IR Indicator 2.2: Greater taxpayer satisfaction with services (Percentage, Custom) Baseline Actual (Previous) Actual (Current) End Target Value 0.00 72.00 72.00 75.00 Date 30-Jun-2014 07-May-2019 13-May-2020 30-Jun-2020 A survey report published on NBR website - http://nbr.gov.bd/uploads/public-notice/NBR_2017_PDF.pdf According to Taxpayer Satisfaction Survey Report, 2017, the following satisfaction index was registered: Comments NBR - 90%, VAT online - 92%, Commissionerate - 59% and Divisional VAT office - 66%. The second Satisfaction Survey Report is expected by October 2020. 6/25/2020 Page 9 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) Disbursement Linked Indicators DLI_IND_TABLE ►DLI 1 DLI 1: VAT Implementation Plan on Track (Output, 34.50, 13%) Baseline Actual (Previous) Actual (Current) FY2019-20 75% complete - VAT Registration module Registration and Return implementation (75% Baseline 2012/13- VAT modules completed and complete). As at May 6, Value Implementation Plan UAT undertaken. A total -- 2019, there are 167,342 approved 159,498 taxpayers have VAT Taxpayers been registered online as registered online. of May 8, 2020 Date -- 07-May-2019 13-May-2020 -- Comments ►DLI 2 DLI 2: Number of active VAT taxpayers (Intermediate Outcome, 8.00, 0%) Baseline Actual (Previous) Actual (Current) FY2019-20 Value 80,000.00 118,317.00 159,498.00 -- Date -- 31-Dec-2019 13-May-2020 -- The online registration module is up and running. Active VAT Taxpayers is 159, 498 as of May 2020, up from a Comments baseline of 94,910 verified during the fifth mission in May 2019. ►DLI 3 DLI 3: Percentage of large taxpayers submitting online returns and tax payments (Intermediate Outcome, 7.50, 0%) Baseline Actual (Previous) Actual (Current) FY2019-20 Value 0.00 0.00 0.00 -- Date -- 31-Dec-2019 13-May-2020 -- Some 44% of the Large Taxpayer Units (LTUs) have submitted their returns for February 2020 online. Another 42% have saved their online returns in draft format but are unable to submit due to some technical problems. The percentage will easily exceed the target of 90% by December 2020. The e-payment of taxes by LTUs will Comments be made available after normal business resumes. Therefore, this indicator is not yet fully met as tax payments are not yet done online. ►DLI 4 DLI 4- (Now merged with DLI-3) (Output, 0.03, 0%) Baseline Actual (Previous) Actual (Current) FY2019-20 Value 0.00 0.00 0.00 -- 6/25/2020 Page 10 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) Date 12-Mar-2014 07-May-2019 13-May-2020 -- Comments ►DLI 5 DLI 5 - Greater transparency of the tax administration (Process, 5.00, 0%) Baseline Actual (Previous) Actual (Current) FY2019-20 Cumulative VAT collection amounts are disclosed on the NBR website for the months of July 2017, October 2017, November NBR releases monthly 2017, January 2018, VAT collection data on February 2018 and April their website but not on 2018. Refund amount is refunds. VOP team has disclosed (in Bangla) by sent a letter to NBR to NBR from 2015-16 till disclose whatever 2017-18 However, the Value 2012/13 amount of refunds they -- disclosed amounts are make. Final survey report yearly figures and not published on NBR monthly as required under website. VAT appeals this DLR. resolved in less than six months on average http://nbr.gov.bd/uploads/ public- notice/DLR_5.1_Scan_17 _Page-2- 17_compressed_.pdf Date -- 31-Dec-2019 13-May-2020 -- Comments ►DLI 6 DLI 6 - Fiduciary Actions (Process, 4.96, 0%) Baseline Actual (Previous) Actual (Current) FY2019-20 Quarterly Fund Utilization Report are submitted by the Program to the Internal Resources Division (Finance Division). 100% of the goods procurement were completed through e-GP. As on the date of 11 out of 23 outstanding Value nil Deloitte’s field visit in audit are resolved. -- December 2019, a significant audit objection (Para 2) was unresolved for more than a year from the date of receipt of audit objections from FAPAD. 6/25/2020 Page 11 of 12 The World Bank Implementation Status & Results Report Revenue Mobilization Program for Results: VAT Improvement Program (VIP) (P129770) Date -- 07-May-2019 13-May-2020 -- There is a lapse of time of deadline to resolve significant audit objections in 6 months. As on the date of Deloitte’s field visit in December 2019, a significant audit objection (Para 2) was unresolved for more than a Comments year from the date of receipt of audit objections from FAPAD. The VIP PIU has been advised to take necessary actions to resolve the observations based on FAPAD’s directions. 6/25/2020 Page 12 of 12