Cost Accounting Rules 2011-the fine-print & sea change

When the Central Government notified The Companies (Cost Accounting Records) Rules, 2011(http://www.icwai.org/icwai/docs/Common_Record_Rules_03jun11.pdf) in June-11, cost accountants(or management accountants as they are better known) and their institute the ICWAI must cried with joy for the extra assignments which these rules entail. After all, more certifications/audits mean more business for professions. But the fine print brings out the devil in the details.

1. Rule 2(c) includes a permanent employee of the company(who has the ICWAI qualification), in the definition of cost accountant. So he is allowed to certify the compliance report that the company maintains appropriate records. To be fair, this is pari materia with the secretarial record keeping, which a company secretary in employment can certify. But it is absurd, because the form of declaration('Form B' does not merely ask reassurance that records have been maintained. The wording is nearly a replica of what the statutory financial auditor has to give. I do not understand what they wish to achieve here. Do they expect a permanent employee to admit that 'I/We have/have not obtained all the information and explanations, which to the best of my/our knowledge and belief were necessary for the purpose of this compliance report' or even that 'In my/our opinion, the said books and records give/do not give the information required by the Companies Act, 1956 in the manner so required.'. Such matters of opinion should be left to professionals in my opinion. 
2. IT companies(!) will be covered under the definition of processing activities under Rule 2(l)(xi)-(xii). 
3. Mere value addition or services,  are brought under the ambit of 'production activity' under Rule 2(o)(iii) with this masterpiece  “Production Activity”  includes any act, process, or method employed  in relation to -(iii) creation of value or wealth by producing goods or services
4. It is common knowledge that the reconciliation statement in Cost Audit report, is often the starting point of any indirect tax inquiry. But this was not explicit from the format etc. Now, the Govt has dropped the pretense and added a footnote below the reconciliation statement format, to make the department's job even easier.  That footnote reads -----------------------------------------------------------NOTES:(i) For produced/manufactured product groups, use the nomenclature as used in the Central Excise Act/Rules, as applicable.(ii) For services groups, use the nomenclature as used in the Finance Act/Central Service Tax Rules, as applicable.