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It is my option:
When Section 42 of the Companies 2013, applies to all companies, even the private companies also need to file PAS-5 along with PAS-4 with the registrar. As per section 42 read with proviso of rule 14(3) of Companies (Prospectus and allotment of securities) Rules, a copy of PAS-5 along with PAS-4 shall be filed with the registrar within 30 days of circulation of private placement offer letter. therefore it maybe inferred that PAS-5 along with PAS-4 may be filed with registrar.
If it is listed company, do one more compliance, it has to intimate SEBI within a period of thirty days of circulation of the private placement offer letter.
Thanks and Regards
R.Shanmugaraja. B.com, ACS.
Company Secretary
Mobile: 9789604604
U need to file pas 5 & 4 in GLN2 to ROC.