112.4
 
When communicating key audit matters, the fact that there are no disclosures in the financial statements related to a matter determined to be a key audit matter does not relieve the auditor from the requirement to communicate it. An auditor may determine a key audit matter related to the audit for which relevant disclosure requirements do not exist in the applicable financial reporting framework. For example, the implementation of a new IT system (or significant changes to an existing IT system) during the period may be an area of significant auditor attention, in particular, if such a change had a significant effect on the auditor’s overall audit strategy or related t significant risk (e.g., changes to a system affecting revenue recognition
Also, if an auditor determines that it is necessary to include information about the entity in order to effectively describe a key audit matter that has not been disclosed by management and management does not agree to disclose that information, the auditor should reconsider the adequacy of the disclosures in accordance with applicable financial reporting framework. The auditor should communicate the matter as a key audit matter unless law or regulation precludes public disclosure about the matter or in extremely rare circumstances, the auditor determines that the matter should not be communicated in the auditor’s report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.

112.5
 
Generally, the Key Audit Matters section is required to be placed after the Basis for Opinion paragraph and before the Management’s Responsibility paragraph.
In case, ‘Material uncertainty relating to going concern’ section is required as per SA 570(Revised), then KAM section is placed after that section.
Further, regarding placement of KAM section, SA 706 (Revised), “Emphasis of Matte Paragraphs and Other Matter Paragraphs in the Independent Auditor’s Report” provides as under:
When a Key Audit Matters section is presented in the auditor’s report, an Emphasis of Matter (EOM) paragraph may be presented either directly before or after the Key Audit Matters section, based on the auditor’s judgment as to the relative significance of the information included in the Emphasis of Matter paragraph. The auditor may also add further context to the heading “Emphasis of Matter”, such as “Emphasis of Matter – Subsequent Event”, to differentiate the Emphasis of Matter paragraph from the individual matters described in the Key Audit Matters section.