MCA Form PAS-6 and its Applicability 

Form PAS-6 (Reconciliation of Share Capital Audit Report on half yearly basis) and It’s Applicability

Provision:

Filing of Form PAS-6 under Rule 9A(8) of the Companies (Prospectus and Allotment of Securities) Rules, 2014

Objective of the Form PAS-6:

Reconciliation of Share capital Audit Report on half yearly basis By Companies.

Applicability:-

This Rule is Applicable on On Unlisted Public Companies.

Reporting Period Commencement:

They shall come into force with effect from 30th September, 2019. First Reporting Period is 30th September 2019.

Company Responsibility:

  1. 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.
  2. The company shall immediately bring to the notice of the depositories any difference observed in its issued capital and the capital held in dematerialized form.”.

What if Company has Different ISIN 

The e-form PAS-6 shall be filed for each ISIN of securities.

Rule 9A of the said rules applicable on Deemed Public Companies (a Private Company which is subsidiary of Public Company)

Content of E-form PAS-6

  • ISIN (International Security Identification Number).
  • Details of capital of Company held in dematerialised form or physical form.
  • Details of changes in share capital during the half-year.
  • Details of shares held by promoters, directors and KMPs in the form of Demat or physical.
  • Details of number of requests, number of shares and reasons for delay for requests confirmed after 21 days or requests pending beyond 21 days.
  • Details of Company Secretary of the Company, if any.
  • Details of Practicing CA/CS certifying this form.

Non-applicability of Rule 9A

This rule shall not apply to an unlisted public company which is: –

(a) a Nidhi;

(b) a Government company or

(c) a wholly owned subsidiary.

Author Bio

Qualification: CA in Practice
Company: Vaishnavi Agrawal & Co
Location: Gorakhpur, Uttar Pradesh, IN
Member Since: 17 Aug 2019 | Total Posts: 3

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8 Comments

    1. Brajesh Kumar says:

      Dear Kuldeep,

      The ISIN is mandatory for dematerialisation of shares and after Company obtained ISIN from NSDL/CDSL then company can file E-form PAS-6 irrespective of that all its share are in demat form or physical form.
      Hope you got your answer.

    1. Brajesh Kumar says:

      1st reporting period is 30.09.2019 as per MCA circular dated 28.11.2019 and for more info..please see my article on PAS-6.

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