- CA. Anshal Khare
- | Company Law - Articles
- 19 Jul 2020
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- 8 comments
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:
- 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.
- 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.
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Whether PAS-6 is required to be filed for the period April 2019 to September 2019? Form is not accepting this period.
where to fill up information if a person holding shares of a company is a director as well as KMP or promoter of company?
How to write ISIN no as company has not yet obtained ISIN(Shares are still in physical form)
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.
2019. First Reporting Period is 31.03.2020, not 30th September 2019, in my view
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.
But the form is not accepting the period from 01/04/2019 to 30/09/2019
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