DPT-3 NIL Return

Can you please anyone clarify my doubt regarding DPT-3
For this FY-2020-2021 we no need to file DPT-3 for NIL balance in borrowing for all companies is it correct???
Replies (10)
Quick Summary
This discussion clarifies the requirement for filing a NIL DPT-3 return for FY 2020-2021. Generally, if a company has no outstanding borrowings or deposits as of March 31st, a NIL DPT-3 filing is not strictly mandatory according to Rule 16. However, many chartered accountants now advise filing a NIL return as a precautionary measure to maintain a clean compliance record and avoid potential future scrutiny. If there are any outstanding amounts, filing the DPT-3 is mandatory, with penalties for non-compliance.

If there is NIL return then there is no requirement for filing DPT 3 nil

NIL DPT-3 is not required to file as per 
Rule 16.

Nil return not required to file

Borrowings from the bank shall be treated as a deposit if the same gets Covered under Rule 2(1)(c) and it has to be disclosed in DPT-3. The Company has to File DPT-3 unless the Ministry of Corporate Affairs reflects that the Company has been struck off.

Borrowing from any one if having in books as on 31 march need to show in DPT-3

Nil Return for DPT-3 is not required be filed

Rule 16 is very specific that, only details of outstanding borrowing needs to mention. If there is no outstanding then no needs to file this form.

NIL DPT-3 is not required to file
Does unsecured loan from directors is also considered as deposit?

On the question of whether a NIL DPT-3 return is mandatory:

If you have NOTHING outstanding ,  no director loans, no inter-company loans, no shareholder loans, no customer advances ,  as on March 31, 2026, then technically no DPT-3 filing is required. The form is only triggered by outstanding amounts.

However, MCA practice has evolved: most CAs now recommend filing a NIL DPT-3 as a precaution, even when nothing is outstanding. Reasons:
- It creates a clean compliance record (useful during due diligence for fundraising or acquisitions)
- It protects against future scrutiny if a transaction was accidentally classified incorrectly
- The cost and effort is minimal compared to the risk

If you DO have ANY outstanding amounts ,  director loan with declaration, promoter loan, advances from related parties ,  DPT-3 filing is mandatory by June 30, 2026.

Penalty for non-filing: Additional fees under Rule 21 of the Deposit Rules, plus Section 76 prosecution in serious cases.

This ROC annual compliance checklist (https://taxgarden.in/blog/roc-annual-compliance-private-limited-company-india) covers DPT-3 and all other mandatory annual MCA filings with their due dates.

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