DPT 3

[Prashant Agrawal]

Unsecured loan taken 1L and paid whole loan amount within financial year..as there is no outstanding loan..need to file DPT 3 

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Warm Regards,

Prashant Agrawal 

[Kavneet Kaur]

No.

- - -

Thanks & Regards,

CS KAVNEET KAUR

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[Prakash Joshi]

Dear All,

A Pvt Ltd owns a commercial building under construction which it intends to give on lease. During the years, it received a security deposit of 2 crores which is outstanding in its books.

Whether this security deposit needs be disclosed in DPT 3 if yes under which head.

What will the answer if the amount was paid as a part consideration for buying  the space in the building instead of lease 

Thanks 

PC Joshi

[Pankaj Khandelwal]

In my article, “Decoding DPT-3 Filing: Ensuring Corporate Transparency,” I discussed the importance of DPT-3 filing for Indian companies and its role in promoting transparency, compliance, and investor confidence.

For a deeper understanding of why DPT-3 matters and practical compliance tips, read my full article here:
https://lnkd.in/gH4sMa6G

Regards

Pankaj K.

Visit: https://www.linkedin.com/in/cspankaj/recent-activity/all/

[Nishant Jain]

Hi Pankaj,

Security deposite not considered deposit. From your question if I am not it is for supply of goods or services 

Please refer rule 2(1)(c)- point 12(c) of acceptance of deposit rule

If amount was paid for buying space in the building i believe it must treated as advance again for this refer 2(1)(c)- point 12(a) of acceptance of deposit rule.

Advance can't be for more than 365 days 

Nishant jain

Practicing Company Secretary 

+91-8470877451

Delhi 

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[Prakash Joshi]

Hi Nishant,

Many thanks for your reply. The  facts of the matter are as follows.

ABC Pvt. Ltd. is a company having its main objects of software business.During the year 24-25 it has no income from business . It has built a building with large space and intends to give the same on rent to others for office use. 

One person X was interested to take some space for commercial use. In Nov 2024 X  paid Rs 2 crore as advance/security deposit with a condition that if the space is not provided within a certain time then he has an option to opt out of the contract and the amount paid by him will be refunded by ABC Pvt Ltd.

The building construction got delayed beyond the agreed  time. Hence, X opted out of the deal and ABC Pvt Ltd. refudnded 1 cr to him in June 25 and balance will be refunded in coming months.

Given the above facts. Please let me have your considered view how to treat the o/s of 2 cr lying in the books of ABC Pvt. Ltd. as on 31.03.25 in DPT-3,

Most of the views I got are : To show it as an advance for  supply of goods and servives to be adjusted within 365 days. But two people differ one says that main objects of the companyi.e software related business hence the amount paid is not business advance, hence not required to be shown. The other view is that it's not a business advance if the amount is given as a security deposit as the security deposit can not be adjusted against rent and advance rent can't be paid when building is not ready for possession. So he suggests it should be shown under Rule 2(1)(Xii)(C)   an amount received as Security Deposit for the performance of the contract for supply of goods of provision of services.

Please share your views on above accordingly.

All the members are requested please share their views based on their interpretation and practical experience of the similar situation.

Thanks

P C Joshi

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[Nishant Jain]

Hi,

As per me it will not be covered  under rules 2(1)(c) point 12 because it's not a business income.

Also as per the definition of deposit any receipt of money is deposit except as provided under 2(1)(c).

So from my point of view it is deposit accepted from public.

Regards
Nishant Jain

Nishant jain

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[Prakash Joshi]

Thank you Nishant for the clarification.

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[Prakash Joshi]

Hi Nishant 

Pls clarify whether a company into software business can't let the extra space to others. As you see most of the company have own IT towers and they also give the extra available space after their own need  on rent. 

 is it not an activity ancillary to main objects?

Thanks

On Sun, 22 Jun 2025, 09:05 Nishant Jain, <njai...@gmail.com> wrote:

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[Nishant Jain]

Hi Prakash

2-3 points to understand here 

1. You can give space on rent, and collect security deposit will not be considered as a deposit

2. But in your case, the company has not given anything in return for the money collected as a security deposit, and also has not repaid the amount even after the expiry of the agreement.

CS Nishant Jain

Nishant Jain & Associates

#F-10, Om Apartment,

Mundka, Delhi- 110041

Contact at: +91-8470877451

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[Prakash Joshi]

Rs 1 cr already repaid against 2cr. Security deposit in case of rent is  always  without interest. 

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[Roma Gupta]

Hi

There was a bank loan of Rs. 4 lakhs as on 31.03.2024 but it has been repaid as on 31.03.2025 so balance is nil due we need to file DPT 3

Regards 

[Roma Gupta]

Kindly help 

[karan vij]

No need to file dpt-3

Thanks & Regards

Karan Vij

(CS, B.com)

K Vij and Co.
Company Secretaries

Email id: cska...@gmail.com 

Mobile No: +91 8076218320

P 

“Please take care of the environment, print only if necessary

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[c.n. krishnan]

dpt3 not applicable for bank loans

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[Nishant Jain]

Hi Roma Gupta,

Please file the DPT-3  as below:

Sl. No.	Name	Op. balance	Add. During the Year	Repayment during the year	Other Adjustment	Cl. Balance	within 1yr	2 yr	3yr
	Loan from Bank(Please check if it’s a scheduled bank or some other bank)
1	Bank Loan	400000.00	0.00	400000.00	0.00	0.00	0.00	0.00	0.00

DPT-3 applicable for bank loan and required to be reported under head 15 Particulars of receipt of money or loan by a company but not considered as deposits, at the end of financial year, in terms of

clause (c) of sub-rule 1 of rule 2 of the Companies (Acceptance of Deposits) Rules,2014

Best Regards

CS Nishant Jain

Nishant Jain & Associates

#F-10, Om Apartment,

Mundka, Delhi- 110041

Contact at: +91-8470877451

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[Roma Gupta]

Thanks

As loan has been repaid completely do we have to report it now or not???

[Nishant Jain]

Yes, we need to report it as DPT-3 form, also ask for the additions and repayments made during the year.

The manner of reporting is stated in the previous mail.

Best Regards

CS Nishant Jain

Nishant Jain & Associates

#F-10, Om Apartment,

Mundka, Delhi- 110041

Contact at: +91-8470877451

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