The Institute of Company Secretaries of India (ICSI) has submitted a formal request to the Secretary of the Ministry of Corporate Affairs for an extension of the deadlines for filing annual forms, including AOC-4 and MGT-7, for the financial year ending March 31, 2024. The request cites practical challenges faced by companies, such as the time-consuming nature of XBRL filing, which requires detailed tagging of data, leading to difficulties in timely submissions. Additionally, the month of October coincides with significant festivals, such as Diwali, which further hinders compliance. The ICSI also points out frequent technical issues with the MCA website, including slow processing and system downtimes during peak filing periods. Moreover, recent changes in compliance requirements have increased the filing burden for both companies and professionals. Given these factors, the ICSI has requested an extension until December 31, 2024, for these filings without incurring additional fees, which they believe would alleviate the challenges and improve overall compliance rates.
THE INSTITUTE OF
Company Secretaries of India
IN PURSUIT OF PROFESSIONAL EXCELLENCE
Statutory body under an Act of Parliament
(Under the jurisdiction of Ministry of Corporate Affairs)
MCA: OCT:2024 28th October, 2024
Ms. Deepti Gaur Mukerjee
Secretary
Ministry of Corporate Affairs
Government of India
Shastri Bhawan
New Delhi
Subject: Request for Extension of time period for filing of Annual Forms (AOC-4 CFS NBFC (Ind AS), AOC-4(XBRL), AOC-4, AOC-4(CFS), A0C-4 NBFC (Ind AS), MGT-7, MGT-7A for the Financial Year ended 31.03.2024 without levying additional fee- Reg.
Respected Madam,
This has reference to the provisions of Section 137 and Section 92 of the Companies Act, 2013, which mandates the filing of financial statements and Annual Return by every company with the Registrar within thirty days and sixty days, respectively, from the date of the annual general meeting.
We wish to submit that various communications have been received from the stakeholders requesting extension of the last date for filing of annual forms citing below reasons
- Practical difficulties faced by companies, particularly with respect to XBRL The process of XBRL filing is not only time-consuming but also requires meticulous tagging of specific items and figures. Due to the technical nature of the format, it becomes challenging for companies to complete the filing on time.
- The month of October usually includes major festivals like Diwali and Bhai Duj, causing additional delays in meeting filing deadlines.
- Frequent technical glitches on the MCA website, especially during peak filing periods. The system often faces downtimes and slow processing speeds, making it difficult for companies to upload their documents on time. This has become a recurrent issue, adding to the filing complexities.
- The Changes in the Forms and the Compliance requirement including the MSME Forms have increased the burden on the professionals and the Companies, creating a bottleneck in meeting filing deadline.
- Central Board of Direct Taxes (CBDT) through its circular dated 26th October 2024, outlines the provision for extending the due date for filing income tax returns for the Assessment Year 2024-25, till 15th November, 2024.
In view of the above, we request an extension for the annual filing Forms (AOC-4 CFS NBFC (Ind AS), AOC-4(XBRL), AOC-4, AOC-4(CFS), AOC-4 NBFC (Ind AS), MGT-7, MGT-7A with an extended deadline till 31.12.2024 without levying additional fee. This extension will greatly ease the burden on companies and improve compliance rates.
We would be happy to provide any further information or clarification in this regard upon hearing from your good office.
Thanking You,
Yours faithfully,
CS B Narasimhan
President
The Institute of Company Secretaries of India
