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ECSIN - When Form DIR-12 not filed

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Whether ecsin is to be also generated when you are appointed as an Assistant Company Secretary (qualified) and Form DIR-12 is not being filed?
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Amended regulation says about, Employed whether as CS or OTHERWISE,Now otherwise can be understood in two way -one ,who has been appointed as Compliance officer /Group CS for which GNL-2 filed or any kind of post even Executive , as per my view, you should generate ECSIN, for more clarification email to ecsin @ icsi.edu ,However ICSI should come up with proper guideline, that up-to what extent "Otherwise " can be extended...


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