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Eligibility for filing ben 2 form of mca

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(Querist)
29 July 2019 A pvt. Ltd. Co having two directors who are holding shares of their own co (52% &48%) . Shall this co be liable for filing BEN 2 within 31st July?
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CS Mitesh Mehta

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CS Mitesh Mehta (Expert)
31 July 2019 No. Direct holding is not required to be reported

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