Dear Friend,
It is statutory that FIRC and FC-GPR have to be filed within the stipulated time lines. Upon filing of FC-GPR, RBI will process it and on merits will issue a letter stating that, the shares/securities issued by the company are taken on record. Once such letter is obtained from RBI, the transaction is considered to be completed under Regulatory aspects.
RBI ordinarily would be lenient with regard to delayed filings of FIRC and FC-GPR. I suggest in your case post FIPB approval try to obtain the necessary letter from RBI as early as possible.
I also suggest not to go for compounding procedure for the delayed filings of FIRC and FC-GPR, unless expressly required by RBI. As in your case the forms (though delayed filed) are already on the records of RBI and they have not called for any show -cause for the delay.
I had filed an FC-GPR in the year 2010 wherein delay was there. But till now we have not received any kind of notice. Further we have already obtained the necessary letter from RBI recording the transaction.
Request other members to give their opinions.
Thanks and Regards,
Suresh Kumar V
Company Secretary
91-9849991201