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Mca amnesty 2026

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(Querist)
04 May 2026 There is a pvt ltd company incorporated on 4 may 2018 and hasn't done any compliances post incorporation. No bank account has been opened as INC 20A was not applicable prior to November 2018. Not even subscription money received. The original subscribers are not traceable. The company is still active. New directors were appointed via DIR 12 on 16 aug 2024 and 16 may 2025 respectively and old directors were removed on the same respective dates. Now the new directors want to file all the pending roc compliances i. e. ADT 1, AOC 4, MGT 7A.
My doubts are -
1. Can I file them without receiving the subscription money or should I receive the subscription money in cash.
2. When can I show the transfer of shareholding? Before receiving subscription money or after.
3. Can the current directors sign the documents for FY 18-19 to 23-24?
Please help and guide.
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Aashok Kumar Sharma online

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Aashok Kumar Sharma online (Expert)
04 May 2026 * ❌ Don’t file blindly without fixing share capital
* ✔ First regularise subscription/allotment
* ✔ Then file pending ROC forms
* ✔ Current directors can sign past filings

Before filing pending ROC compliances, you must regularise share capital (subscription money & allotment) because filings without it may be invalid. Share transfer can happen only after proper allotment, and current directors are allowed to sign past financials. The case requires careful structuring, not just form filing.
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