Wednesday, 18 January 2017

Fast Track Exit of Company (Inoperative Co’s) under Companies Act 2013

Fast Track Exit of Company (Inoperative Co’s)

Relevant Sections under Companies Act 2013;

Section 248, 249, 250,251, 252 under Chapter XVIII (Removal of names of Companies from the Register of Companies)
Effective Date;
26th December 2016
Brief Idea about Striking off Company Name under Companies Act 2013
Earlier under Companies Act 1956, there was eForm FTE under which companies used to apply for striking off name from the register of Companies as the companies were inoperative since incorporation and not doing any business from last one or two years but on 26th December 2016, MCA came up with a notification wherein Section 248 to Section 252 got notified and new procedures and new forms have come up for striking off name of the company voluntarily.
Eligibility Criteria;
Check I: It is important to note that striking off voluntarily can only be applied by small companies and following list of companies are not eligible to apply for striking off;
1.      Listed Companies
2.      Companies registered under section 8
3.      Companies having charges which are pending for satisfaction
4.      Companies whose application for Compounding is pending
5.      Companies against which any prosecution for an offence is pending in any court
6.      Vanishing Companies
7.      Companies that have been delisted due to non-compliance of listing regulations or listing agreement or any other statutory laws;
8.      Companies where inspection or investigation is ordered and being carried out or actions or such order are yet to be taken up or were complete but prosecutions arising out of such inspection or investigation are pending in the court.
9.      Companies which have accepted public deposits which are either outstanding or the company is in default in repayment of the same;
10.  Companies where notices under section 234 of CA 1956 or 206 or 207 of the Act, 2016 have been issued by the Registrar or Inspector and reply thereto is pending or report under section 208 is pending or where any prosecution arising out of such inquiry or scrutiny, if any, is pending with the court.
Check II:
Only the Companies which have;
a.       failed to commence its business within one year of its incorporation; OR
b.      is not carrying on any business or operation for a period of two immediately preceding financial years and has not made any application within such period for obtaining the status of a dormant company under section 455
can apply for striking off of Company
From where to check;
Check the Financial Statements of the Company last filed or if the master data shows that there is no annual return filed since incorporation along with check the bank statement of the company to know the real situation.
Check III:
The Company can not made any application for the strike off of the Company if any time in the previous 3 months the company has done any of the below mentioned workings:
i.                    Has Changed its name or
ii.                  Has Shifted its registered office from one State to another;

iii.    has made a disposal for value of property or rights held by it, immediately before cesser of trade or otherwise carrying on of business, for the purpose of disposal for gain in the normal course of trading or otherwise carrying on of business;

iv.    has engaged in any other activity except the one which is necessary or expedient for the purpose of making an application under that section, or deciding whether to do so or concluding the affairs of the company, or complying with any statutory requirement;

 v.    has made an application to the Tribunal for the sanctioning of a Compromise Or Arrangement and the matter has not been finally concluded; or

vi.    is being wound up under Chapter XX, whether voluntarily or by the Tribunal.

 eForms to be filed for Striking off of the company;

-          eForm MGT 14
-          eForm STK 2 having attachments like Form STK 3 & Form STK 4 and other attachments

Steps to be followed to apply for Striking off of the company;

Step 1: Board Meeting:
Passing of Board resolution for the purpose of Strike off of Company, to call General Meeting and to authorize any director of the Company to file application with Registrar of Companies
Step 2: Check for Liabilities in Company and closing of Bank Account(s), if any:
After passing of Board resolution if there is any liabilities in the Company. Company will set off all the liabilities before next step and close the bank accounts, if any. Check fr Secured Loans or unsecured Loans and the Balance sheet of the company, if available.
Step 3: Extra Ordinary General Meeting:
Company will hold the Extra Ordinary general meeting of members of the Company and pass a resolution for strike off of Companies with the approval of 75% of members as per paid up share capital of the Company. After passing of Special resolution company will file MGT-14 within 30 days of passing Special Resolution.
Step 4: Filing of eForm STK 2 with necessary attachments:
Application for striking off of Company shall be made in eform STK-2 . E-form STK-2 shall be signed (Affixation of DSC) by a Director. Director should be authorized by the Board for such purpose. Also, the form has to be attested by the Professional. Government fees for filing eForm STK 2 is Rs. 5000/-. The form shall accompany the following documents/ attachments;
Attachment – STK-2: 
i.                    Indemnity Bond from Every Director in format as prescribed in Form STK-3(Same as was done under FTE)
ii.                  Statement of Accounts certified by CA. Statement should not be older than 30 days from the date of application. (Same as was done under FTE)
iii.                An Affidavit from every Director as prescribed in Form STK-4(Same as was done under FTE)
iv.                CTC of Special Resolution duly signed by each Director (Newly added)

v.                  Statement regarding pending litigations, if any, involving Company (Same as was done under FTE)

vi.                NOC from the appropriate concerned authority, if required (RBI, IRDA, Housing Finance, SEBI etc.) (Same as was done under FTE)

Place of application on Website:

Earlier in eForm FTE the company was not required to place copy of application at its website while vide MCA notification dated 26th December 2016, the Company will place the copy of application on its website till the disposal of the application. (Newly added).

But there is no clarity as if the company doesn't have website as it didnt do any business since registration, so, in that case, placing of application on website is to be complied or not?

Undertaking from Director – Discharge of Liability:

The Registrar, if feel necessary, obtain necessary undertakings from the managing director, director or other persons in charge of the management of the company that the sufficient provision has been made for the realization of all amount due to the company and for the payment or discharge of its liabilities and obligations by the company.

Declaration from any Director:

i.                    The directors will give following below mentioned declarations:

ii.                  The application has been in accordance with the conditions mentioned under sub section (1) and (2) of section 248 and sub section (1) of section 249:

iii.                There is no inspection or investigation ordered and carried out or yet to be carried out or being carried out against the company and where inspection or investigation have been carried out , no prosecution pending in any court arising out of such inspection or investigation;

iv.                The company is neither having any public deposit which are outstanding nor the company  is in default in its repayment or interest thereon ;

v.                  The company does not have any outstanding loans, secured or unsecured;

vi.                The company does not have any dues towards income tax .VAT, excise duty, service tax or any other duty, by whatever name called, payable to  the central  government or state government,  statutory authority or local authority;

vii.              All other liabilities of the company have been settled or discharged or extinguished;

viii.            All the requirements of the act and rules made thereunder relating to removing the name of the company from the register of companies and matters incidental or supplemental thereto have been complied with;

ix.                To the best of my knowledge and belief, the information given in this application and attachment is correct and complete;

x.                  the requisite fee has been paid.


It is important to note that eForm FTE may be available at MCA but new eform STK 2 has been notified w.e.f 26th December 2016, so it is recommended not to use old eForm FTE for Striking off of Company. Section 248 to Section 252 got notified and new procedures and new forms have come up for striking off name of the company voluntarily.

For more details, contact CS Neha Seth at 9871903449 or email us at csnehaseth@gmail.com or csnehaseth.cp@gmail.com



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