Tax Consultant
724 Points
Posted on 10 June 2026
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.