The Office of the Registrar of Companies (ROC)
Ministry of Corporate Affairs
Sanjay Complex, 'A' Block
3rd Floor, Jayendraganj
Gwalior, M.P. - 474009
Sub: Application for seeking extension of time for holding Annual General meeting for the financial year ended 31.03.2020
This is with reference to the above subject and MCA vide General Circular no. 28/2020 dated 17th August, 2020 has issued Clarification on Extension of Annual General Meeting (AGM) for the financial year ended as at 31.03.2020 as per Section 96 of the Companies Act, 2013.
The Annual General Meeting of the members of the Company in respect of the year ended on 31st March, 2020 is required to be held by 30th of September 2020. But there is hardship on the part of the Company to hold its Annual General Meeting within the stipulated time period. The reasons and facts for seeking extension for the same are as under for your kind perusal and consideration:
1. As the present COVID-19 situation was there since March, 2020, the Registered office of the Company also falls under Red Zone then for a longer duration and Company's auditors also belongs to ------Name of city from where auditor belongs to ----------------. which was almost closed for a long period, so it is not much practically possible for us to complete our reports and desired documents updated in efficient and effective manner.
2. The Company's liquidity position has been also impacted due to COVID-19, but this situation could be managed to an extent with the support of our bankers, customers and corporate clients and all concerned stakeholders.
3. As far as pertaining to conduct Meeting(s) through virtual or other audio visual means, there is also very large arrangement and requirement, such as any service provider etc. and have to make arrangement of proper connectivity with all our channels and available resources etc.
4. As the Company is a Listed / Public / Company, the provisions pertaining to SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and other SEBI Regulations, will also be applicable and compliant by the Company. However, there have been various relaxations and extensions given for compliances and submission to the listed entities and Company since the situation of COVID-19 complying the same in consultation with the auditors as far as practically possible taking due extension and complying the norms effectively then.
5. Presently, in compliance of various Circulars of SEBI, MCA and notifications from all regulatory authorities, we are conducting and managing the things in a prudent manner and majorly time bound relaxation has been provided for effectively managing the work and compliances till date.
However, these above mentioned facts arises due to the present COVID-19 crisis and the situation persists is totally beyond control. We also affirm that, we are always in compliant of all applicable laws and done all compliances and filings with ROC in stipulated timeframe.
We are also enclosing herewith the Board Resolution and brief particulars showing details for extension of AGM for your kind perusal.
In light of the above facts, we hereby humbly urge you to kindly provide us extension for Annual General Meeting for the financial year ended 31.03.2020 for a specified period.
Kindly receive the above for the needful, consider the same and acknowledge receipt, please.
For ----------------- Pvt. Limited / Limited
-----Name of Authorised Person -----
Whole Time Director /Director / or any other mention post of person
DIN----- Membership No. if any
1) Board Resolution.
2) Brief Particulars for extension of AGM for the financial year ended 31.03.2020.