Clarification on Transfer of Subscription Money-FOR FILING INC-20A

[Anupma Mittal]

Dear All,

Can you please confirm whether it is appropriate to transfer the amount of subscription money to the Company’s bank account from a subscriber’s/shareholder’s joint bank account, or whether the transfer should strictly be made from their individual bank account only?

Thank You

CS ANUPMA

[Deepanshu Mittal]

Hi Anupma,

• Preferred Practice (and MCA’s implicit expectation):
  Subscription money should come from a bank account in the sole name of the subscriber. This provides a clear audit trail and avoids future questions from the ROC, auditors, or during inspection.

• Joint Bank Account Scenario:
  If the subscriber uses a joint bank account, it may still be acceptable provided the subscriber is one of the joint holders.

• In such cases, obtain a declaration/No Objection Certificate (NOC) from the other joint holder(s) stating that they have no objection to the funds being used for the purpose of subscribing shares in the company.

• Maintain documentary evidence (bank statement highlighting the transfer, subscriber’s PAN, NOC) to establish the identity and source of funds.

• 
  

• Conclusion

  ✔️ Best Practice: Subscription money should be remitted from the subscriber’s individual bank account.
  ✔️ Joint Account Acceptable: Permissible if the subscriber is a joint holder, but ensure a proper NOC and documentation to prove the funds are indeed of the subscriber.

• 
  

• Warm Regards, 
  CS Deepanshu Mittal
  Mob: 8130710162
  Email: cs.deepan...@gmail.com

  
  

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Warm Regards, 

CS Deepanshu Mittal

Mob: 8130710162

Email: cs.deepan...@gmail.com

[Paresh Shah]

I think there is no need for NOC if the subscriber is the first named holder of the bank account.

Yahoo Mail: Search, organise, conquer

On Tue, 16 Sept 2025 at 16:23, Deepanshu Mittal

<cs.deepan...@gmail.com> wrote:

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