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Mca amnesty 2026

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There is a pvt ltd company incorporated on 4 may 2018 and hasn't done any compliances post incorporation. No bank account has been opened as INC 20A was not applicable prior to November 2018. Not even subscripttion money received. The original subscribers are not traceable. The company is still active. New directors were appointed via DIR 12 on 16 aug 2024 and 16 may 2025 respectively and old directors were removed on the same respective dates. Now the new directors want to file all the pending roc compliances i. e. ADT 1, AOC 4, MGT 7A. 

My doubts are - 

1. Can I file them without receiving the subscripttion money or should I receive the subscripttion money in cash. 

2. When can I show the transfer of shareholding? Before receiving subscripttion money or after. 

3. Can the current directors sign the documents for FY 18-19 to 23-24?

Please help and guide. 

Replies (1)

Before filing pending ROC compliances, you must regularise share capital (subscripttion money & allotment) because filings without it may be invalid. Share transfer can happen only after proper allotment, and current directors are allowed to sign past financials. The case requires careful structuring, not just form filing.

  • ❌ Don’t file blindly without fixing share capital
  • ✔ First regularise subscripttion/allotment
  • ✔ Then file pending ROC forms
  • ✔ Current directors can sign past filings


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