ICSI has written a letter to Ministry of Corporate Affairs and requested for extension of timelines due to COVID-19 of E Form – MSME FORM-1, E Form- PAS-6 and Form 11- LLP.

THE INSTITUTE OF Company Secretaries of India
(Under the jurisdiction of Ministry of Corporate Affairs)

MCA: 2021 15th April, 2021

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

Subject: Request for extension of timelines due to COVID-19-reg.

Respected Sir,

As your goodself is aware that second wave of COVID-19 pandemic is spreading fast and economy is again gripping in the crisis. The situation in the major cities is again worsening and government has imposed various restrictions to curb the impacts. In these challenging times stakeholders are finding it difficult to meet the ends and function smoothly. Considering the current crisis, we request your esteemed office to consider relaxations in due dates of the following compliances:

S. No. Rule / Section Particulars Suggestion
1 E Form – MSME FORM-1

Pursuant to Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order, 2019 dated 22 January, 2019 issued under Section 405 of the Companies Act, 2013.

All specified companies, who get supplies of goods or services from micro and small enterprises and whose payments to micro and small enterprise suppliers exceed forty five days from the date of acceptance or the date of deemed acceptance of the goods or services as per the provisions of section 9 of the Micro, Small and Medium Enterprises Development Act, 2006, shall submit a half yearly return to the Ministry of Corporate Affairs stating the following:

a. the amount of payment due and

b. the reasons of the delay

Such return is to be filed by 31st October for the period from April to September and by 30th April for the period from October to March.

The filing date for the period from October, 2020 to March, 2021 may be extended upto 30th June, 2021.
2 E Form- PAS-6

Pursuant to Rule 9A (8) of The Companies (Prospectus and Allotment of Securities) Rules, 2014.

Every unlisted public company governed by this rule shall submit Form PAS-6 to the Registrar with such fee as provided in Companies (Registration Offices and Fees) Rules, 2014 within sixty days from the conclusion of each half year duly certified by a Company Secretary in practice or Chartered Accountant in

The filing date for the half year ended 31st March, 2021 may be extended upto 30th June, 2021.

3 Form 11- LLP

Annual Return of Limited Liability Partnership

Pursuant to Section 35(1) of Limited Liability Partnership Act, 2008 read with Rule 25(1) of Limited Liability Partnership Rules, 2009. Every LLP is required to file Annual return in LLP 11, within sixty days of closure of financial year.

The filing date for the year ended 31st March, 2021 may be extended upto 30th June, 2021.

We hope that the above submissions would be considered favorably.

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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