Institute of Company Secretaries of India

MCA: 2021 Dated: May 19, 2021 

Shri Rajesh Verma, IAS
Ministry of Corporate Affairs
Government of India
Shastri Bhawan, Dr. Rajendra Prasad Road
New Delhi -110001 

Subject: MCA General Circulars 06/2021 and 07/2021 dated May 3, 2021 w.r.t relaxation in levy of additional fees in filing of certain forms under the Companies Act, 2013 and LLP Act, 2008 – Reg.

Respected Sir,

We extend our gratitude to the Ministry of Corporate Affairs (MCA) for providing relaxations and relief to the stakeholders amidst COVID-19 pandemic. We would like to draw your kind attention towards relief provided by MCA vide General Circulars Nos. 06/2021 and 07/2021 thereby providing additional fee waiver for specified forms.

In this regard, we wish to submit that the relief was provided for filing of only certain specified forms under the Companies Act, 2013. Further, we also bring to your kind notice that no relief has been granted for filing of forms under the LLP Act, 2008 in the aforementioned Circulars, though the same was intended to cover LLPs also.

We would also like to bring to your kind attention the relief extended by MCA vide General Circular No. 11/2020 dated March, 24, 2020 stating that ‘No additional fees shall be charged for late filing during a moratorium period from 01st April 2020 to 30th September 2020, in respect of any document, return, statement etc., required to be filed in the MCA-21 Registry, irrespective of its due date’, which reduced the compliance burden, including financial burden of Companies/ LLPs at large.

Accordingly, considering the current crisis, we request your esteemed office to consider providing relaxation by waiver of additional fee in respect of the forms under the Companies Act, 2013 and the LLP Act, 2008, which falls due for filing during April 1, 2021 to May 31, 2021 in line with the relaxation provided vide MCA General Circulars No. 06/2021 and 07/2021 referred above, so as to enable filing of such forms without additional fees, upto July 31, 2021.

We hope that the above submission would be considered favourably.

We shall be pleased to provide any further information in this regard on hearing from your goodself.

Thanking You,
Yours faithfully, 

(CS Asish Mohan)

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