Receiving multiple query about filling of DPT-3.
People are asking about number of DPT-3 are required to file for FY ended on 31-03-2019 including one time return of deposit?
MCA has inserted an explanation to rule 16 and a new rule 16A vide notification dated 22-01-2019.
Explanation to rule 16:
[Explanation- It is hereby clarified that Form DPT-3 shall be used for filing return of deposit or particulars of transaction not considered as deposit or both by every company other than Government company.]
Earlier DPT-3 was required to be filed annually, by 30th June only for amount covered under Deposit. By virtue of explanation inserted by notification dated 22-01-2019, DPT-3 is now required to be filed by the every company other than Govt Co. for transaction which is not consider as Deposit according to deposit Rule 2(1)(c)
Accordingly, one DPT-3 is required to be filed for FY 2018-19 as Return of Deposit or Transaction not covered as Deposit under rule 2(1)(c).
New Rule 16A (Amended by notification dated 30-04-2019):
“Every co. other than Govt. Co. is shall file a onetime return of outstanding Money as on 31-03-2019 which were not considered as Deposit pursuance to rule 2(1)(c) during 01-04-2014 to 31-03-2019.”
It is a disclosure requirement and DPT-3 is required to be filed separately for that purpose with respect to o/s Money as on 31-03-2019.
Someone has a view that One time return cover transaction during FY 2018-19 and therefore annual return under Rule 16 (discussed in the first part of this article) not required to be filed.
My View on the DPT-3 are:
Separate DPT-3 are required to file for Annual Return of Deposit under Rule 16 as well as for Disclosure under Rule 16A
DPT-3 is required to be filed even if o/s loan as on 31-03-2019 is Zero and during the period 01-04-2014 to 31-03-2019 there is transaction of deposit or loan.
As it is a disclosure requirement and covers period 01-04-2014 to 31-03-2019. Don’t Forget to attach in DPT-3 under Additional Attachment a Year Wise details of transaction not covered under deposit in pursuance to rule 2(1)(c) for the periods 01-04-2014 to 31-03-2019 mentioning the fact under remarks as the loan has been repaid.