Hi Lina,
If you are qualifying Part A for insufficient evidence for the property, then you would absolutely have to qualify Part B and likely issue an auditor contravention report, because the size of the property’s value would put it in scope.
I have a few and it will come down to:
*Valuation – do you have sufficient evidence per the ATO QC26343 (sufficient sales of similar properties around 30th June of the year in question)
*Ownership – you’ve headed off
*Reg 13.14 – can you get a title search showing there is no charge over the fund assets (QC73156)
*Leases – ATO are asking for these for s109 (arm’s length) and whether rented to a related party (s62/s65)
If you can’t get all or most of this, I think you’ll be qualifying Part B for multiple issues and an ACR will be inevitable.