STK-2 Form Resubmission

[AJAY YADAV]

Hello Everyone,

I am seeking guidance regarding a query received during the STK-2 resubmission process concerning the filing of Form DPT-3.

The MCA's initial query requested an update to the annual return of deposits per Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014. We responded by stating that the company has had no outstanding loans or deposits for the last two years and, as per Rules 16 and 16A, filing a NIL return is not mandatory. We also provided a signed declaration from the Directors.

However, we have received a second resubmission request stating that our previous clarification is not justifiable.

For additional context, the company last filed Form DPT-3 in FY 2018-19. Since then (FY 2019-20 to FY 2024-25), the company has had no secured or unsecured loans, no loans from directors, no advances from customers, and no deposits.

Could you please advise on the best course of action? Specifically:

1. Should we proceed with filing Form DPT-3 for FY 2019-20 through FY 2024-25, despite the significant late fees involved?

2. Should we provide a more detailed reply reiterating that there are no reportable amounts or deposits for the periods in question?

The Last date of resubmission is 03/04/2026. I look forward to your suggestions.

Thanks & Best Regards

CA CMA CS Ajay Yadav

(FCA, FCMA, ACS, M.com, P.G.D.F.M, PEER REVIEWER-ICAI)

+91 982187 2529

[Gulap Agarwalla]

If the loans are outstanding as on 1st April but nill outstanding as on 31st March. Then also file for that 1 year.

Further pls cross check balance sheet properly if any reportable amount 

Best Regards

CS Gulap Agarwalla

B.Com(H), M.Com(H), CS (Company Secretary)

Ph. No: 98594-91059

Email: gulapaga...@gmail.com

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[Vandana Jain]

if any amount exists in 4 columns in dpt-3, i.e. opening balance, additional loan during the year, repaid during the year and closing balance, then DPT-3 should be filed.

Furthermore, keeping in view the wordings of second resubmission remarks, it seems that even NIL dpt-3 should also be filed even if all the 4 columns contain zero amount. 

To view this discussion visit https://groups.google.com/d/msgid/gyan-gurukul-cs-divesh-goyal/CAPzA3vXr5EotVhXbUghu7eQVB9S8Cvu1cXOfkRe%2BmANJq1LmkA%40mail.gmail.com.

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CS VANDANA JAIN

Company Secretary

201, Western Business Centre

1/6, New Palasia, 

Indore (M.P.) 452001

Mobile: +91-9589998779