Transactions before filing INC 20A.

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amit

Developer

26 Points Posted on 22 June 2023

I have opened a bank account for my private limited company and was not aware that transactions are not allowed before filing INC 20A. I made a few transactions to test ATM, internet banking, and online payments. What options do I have now?

Ignore these transactions.
Reverse the debit transaction.
Upload NEFT/IMPS receipts instead of a bank statement.
Open a new account.

My second query is, can a shareholder deposit their share capital in installments through multiple transactions?

Replies (3)

Quick Summary

If you've made transactions before filing your company's INC 20A form, you have several options, including reversing debits or uploading payment receipts. It's crucial to note that commercial transactions like billing clients or signing revenue contracts are prohibited before INC 20A is filed and accepted. Shareholders can deposit share capital in instalments, but all share subscription money must be received before filing. Missing the 180-day window for INC 20A can lead to the company being struck off and penalties for directors.

Rama chary Rachakonda

Master in Accounts & high court Advocate

7021 Points Posted on 22 June 2023

please follow this link for your querries of INC 20A.

https://www.tesz.in/question/form-inc-20a

Tax Garden

Tax Consultant

2084 Points Posted on 06 May 2026

A company incorporated after November 2018 cannot commence any business or use any borrowing powers until INC 20A is filed under Section 10A of the Companies Act. Before filing, you can open a company bank account, receive the share subscripttion money from the subscribers listed in the MOA, and cover incorporation-related expenses from that account. Commercial transactions like billing clients, signing revenue contracts, or receiving payments from customers should wait until INC 20A is filed and accepted by the MCA portal. If the 180-day window is missed, the company can be struck off and directors face a penalty of Rs 1,000 per day.

Aashok Kumar Sharma

Finance/Compliance Consultant

77979 Points Posted on 06 November 2026

Minor test transactions are a low-risk technical issue. Fix it promptly:

• Sec 10A(1): a company with share capital shall not commence business or exercise borrowing powers until it files INC-20A (within 180 days of incorporation), declaring that subscribers have paid the subscripttion money. Test debits and credits (ATM, net banking checks) are not really "commencing business", and opening a bank account is in fact a prerequisite. But keep them minimal.

• Do this:

1. Deposit the subscripttion money from each subscriber (by cheque or bank transfer from their own accounts).

2. File INC-20A with the bank statement showing the subscripttion receipt.

3. Record the test transactions properly (or reverse them).

• Don't make business payments (vendor payments, sales receipts) before INC-20A. The penalty for commencing business without the declaration is Rs 50,000 on the company and Rs 1,000 a day (max Rs 1 lakh) on each officer in default (Sec 10A(2)).

• If 180 days have already passed, file with additional fee and consider suo motu adjudication (Sec 454) to limit exposure.