Annual Return of Dormant Company

We had obtained dormant status of a Private Limited Company during the previous year 2019-20, and as the company was dormant as on 31/03/2020, we prepared and submitted Form MSC-3 during April 2020, as prescribed under Companies Act, 2013.

During July-August 20, we again changed status of the company to Active Company, my query is "Whether we need to file AOC4 & MGT 7 for the period ended on 31/03/2020, as master data of the company is showing balance sheet filed up to 31/03/2019". We raised a ticket on MCA Portal but they didn't had any satisfactory answer and said "Consult a professional".

Relevant Act do not impose any obligation but I want to be sure to avoid any future penalty.

Thanking you in anticipation.

Your query is valid and shows good attention to compliance. Here's the clear and practical answer based on the Companies Act, 2013, and MCA practices regarding dormant companies:

🔍 Situation Recap:

Your company was dormant as of 31/03/20.
You filed MSC-3 (the annual return for dormant companies) in April 2020, as required.
In July-August 2020, the status was changed back to Active Company (via Form MSC-4, presumably).
MCA Master Data shows last balance sheet filed is up to 31/03/19.

Now you’re wondering:

Do you still need to file AOC-4 (financial statements) and MGT-7 (annual return) for FY 2019–20, even though the company was dormant on 31/03/2020?

✅ Legal Position:

Under the Companies Act, 2013:

Section 455 (Dormant Companies) allows a company to remain inactive and file MSC-3 annually instead of AOC-4 & MGT-7.
As per Rule 7 of the Companies (Miscellaneous) Rules, 2014:

“A dormant company shall file a 'Return of Dormant Company' annually... in Form MSC-3.”

So:

For a company that remained dormant throughout the financial year, filing MSC-3 is sufficient compliance.
AOC-4 and MGT-7 are not applicable for that year if the company did no financial activity and remained dormant till 31/03/2020.

📌 Your Case:

Since the company:

Was dormant throughout FY 2019–20,
Filed MSC-3 for the year ending 31/03/20,
And became active after the end of FY 19–20 (i.e., in July–Aug 2020),

👉 You are not required to file AOC-4 and MGT-7 for FY 19–20, provided:

The company did no financial transaction in FY 19–20.
The company maintained dormant status through 31/03/20.

⚠️ MCA Master Data Issue:

The master data showing "balance sheet filed up to 31/03/19" is because MSC-3 filings are not reflected there — only AOC-4 filings are shown in the master data view. This is a known limitation of the MCA portal, but it doesn’t affect compliance.

✅ Final Answer:

Question	Answer
Do you need to file AOC-4 & MGT-7 for FY 2019–20?	No, since MSC-3 was filed and company was dormant throughout the FY.
Is master data mismatch a problem?	No, MSC-3 is not shown in public master data.
Any penalty risk?	No, as long as no business activity was done and MSC-3 was filed on time.