Amendment to MoA & AoA of Section 25 Company

Dear Forun Member,

We are incorporated as a Section 25 and doing activities in support of education. Following our 3-6 months operation, we've been called for hearing by Income Tax (Exemption) authorities for exemption under Sec 12A and Sec 80G of IT Act. They've asked us to amend both MoA and AoA which requires lot of words such as "or Abroad",  "or elsewhere in the World" or "and Foreign", "commercial", "Business/trade" etc.  to be deleted.

After a brief search on the forum, I've noted that our auditor needs to file FORM 23 alongwith amended MoA and AoA. But, I'm bit confused as the procedure is different then conventional companies. Can anyone in the forum help us to clarify the steps involved:

(1) Call a general meeting and pass a Special Resolution by the board to authorise Chairman to amend MoA & AoA. This is our internal meeting and send letters to our board members only or shall we need to do a public notice?

(2) Special Resolution Number - do our board meeting special resoultion has to be registered with RoC and get a number or this number is our internal number?

(3) The authorised Director countersigns the amended MoA and AoA. Is this agreeable? Or do the 2 subscribers & witnesses need to sign again under the subscribers page.

(4) If subscribers need to sign again, is it required both promoters signature? In our case, one of the promoter is in Overseas? and what is the procedure for it.

(5) Approach Regional Director with the amended MoA and AoA by filing FORM24A option "Others" and in parallel submit Hard copy of MoA and AoA in triple. Is this correct. Regional Director will vet the changes and then forward the same to RoC. Is this correct?

(6) Once RD is signed/approved the amendments of MoA and AoA, submit FORM23 (mention under point 7, amendments to clause) with regional director approved copies MoA and AoA alongwith signed Special Resolution. Is this correct.

Kindly clarify these.

Thanks,

Priya

Replies (4)

Hi, if you have successfully done the process, can you please let me know the procedure. Thanks.

in my view, the procedure will not be different from that of a regular company.

 

1) Board Resolution and fixing date of egm and approval of notice

2) egm wherein MOA/AOA is amended by way of sp. resolution

3) Filing form 23 with Roc. ROC approves the form.

As regards Regional Director, I believe approval from that office is not required.

 

View of other members requested.

I agree with the step of taking approval of Regional director for alteration in MOA & AOA of a section 25 company but confused whether it should be before passing special resolution or after passing as the MOA usually contains the clause of prior approval of RD before altering the MOA.

Please clarify on the point.

 

CS Ruchika Jain

Ms. Ruchika

 

Section 25(8)(a) provides that a company that has received a license under  this section, shall not alter the provisions of its Memorandum as regards its objects except with the previous approval of the CG(RD).

 

It was held in the case of C.R. Singhania V Garware Club House (2003)  that the license issued u/s 25 of the Companies Act, 1956, specifically provides that no alteration shall be made to the AOA of the Company unless the alteration had been previously submitted to and approved by the CG (RD).

 

Regards

Ajay   

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