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Date: 2019-01-02 Category: Not Applicable State: Tamil Nadu Country: India

MINISTRY OF LAW AND JUSTICE - Legislative Department - THE COMPANIES AMENDMENT ORDINANCE, 2018 - No. 9 OF 2018

Issued by Part IV-Section 4 · Not Applicable

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Executive Summary & Key Takeaways

**Executive Summary** This document is a republication of the Companies (Amendment) Ordinance, 2018, promulgated by the President of India and effective immediately. The ordinance amends the Companies Act, 2013, primarily concerning penalties for non-compliance and certain procedural requirements. It was issued because Parliament was not in session, and immediate action was deemed necessary. **Key Points / Main Content** * **Commencement of Business:** * Companies incorporated after the commencement of this ordinance with share capital must file a declaration with the Registrar, verifying that subscribers to the memorandum have paid for their shares and verify their registered office. * Failure to comply results in a penalty for the company and its officers. * If a declaration is not filed within 180 days, the Registrar may initiate action to remove the company's name from the register. * **Registered Office Verification:** * The Registrar may conduct physical verification of a company's registered office if there's reason to believe it's not conducting business. * If non-compliance is found, action can be taken to remove the company from the register. * **Conversion of Public to Private Company:** * Alterations converting a public company into a private one require approval from the Central Government. * **Discount on Shares:** * If a company fails to comply with provisions related to discounts on shares, the company and defaulting officers are liable for penalties and must refund the monies received with interest. * **Charge Registration:** * The Registrar may allow registration of charges created before or after the ordinance commencement within specified periods, with additional fees. * Willfully providing false or incorrect information or suppressing information during charge registration leads to action under Section 447 of the Act. * **Rectification of Register of Charges:** * The Central Government can direct the extension of time for intimating payment or satisfaction of a charge or rectification of omissions or misstatements. * **Annual Return Filing:** * Failure to file annual returns results in penalties for the company and its officers. * **Disclosure of Interest by Directors:** * Non-compliance regarding the disclosure of interest results in penalties for the promoter, director, manager, or key managerial personnel. * **Penalties and Other Amendments:** * Numerous sections related to penalties have been amended, replacing imprisonment with monetary penalties or adjusting the amounts. * **Non-compoundable Offences:** * Any offence which is punishable under this Act with imprisonment only or with imprisonment and also with fine shall not be compoundable * **Repeated defaults:** * Where a company or an officer of a company or any other person having already been subjected to penalty for default under any provisions of this Act, again commits such default within a period of three years from the date of order imposing such penalty passed by the adjudicating officer or the Regional Director, as the case may be, it or he shall be liable for the second or subsequent defaults for an amount equal to twice the amount of penalty provided for such default under the relevant provisions of this Act. **Impact Analysis** **Companies** * **Impact:** Companies incorporated after the ordinance must comply with new requirements for commencing business and verifying their registered office. * **Action Required:** File required declarations and verifications with the Registrar within the specified timeframes and take steps to ensure ongoing compliance. **Company Directors and Officers** * **Impact:** Directors and officers face increased penalties for non-compliance with various sections of the Companies Act. * **Action Required:** Ensure strict adherence to all provisions and timelines outlined in the Act to avoid penalties. **Central Government/Registrar of Companies (ROC)** * **Impact:** The ROC now has additional powers to verify company operations and can take action against non-compliant companies. The Central Government is now responsible for approving conversions of public to private companies. * **Action Required:** Implement procedures for physical verification of registered offices and processing applications for conversion of public to private companies, along with enforcing the changes in penalty amounts. **Tribunal** * **Impact:** Certain powers previously held by the Tribunal have been reassigned to other bodies. * **Action Required:** Refrain from processing applications related to sections impacted by these changes.

Key Entities Referenced

Companies Act, 2013: The principal act being amended. Companies (Amendment) Ordinance, 2018: The ordinance promulgated to amend the Companies Act, 2013. Ministry of Law and Justice: The ministry under which the ordinance was issued.
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© [Regd. No. TN/CCN/467/2012-14. GOVERNMENT OF TAMIL NADU [R. Dis. No. 197/2009. 2019 [Price: Rs. 3.20 Paise. TAMIL NADU GOVERNMENT GAZETTE PUBLISHED BY AUTHORITY No. 1] CHENNAI, WEDNESDAY, JANUARY 2, 2019 Margazhi 18, Vilambi, Thiruvalluvar Aandu – 2049 Part IV—Section 4 CENTRAL ACTS AND ORDINANCES MINISTRY OF LAW AND JUSTICE (Legislative Department) New Delhi, the 2nd November, 2018 / Kartika 11, 1940 (Saka) . The following Central Ordinance promulgated by the President of India is hereby re-published for general Information:— THE COMPANIES (AMENDMENT) ORDINANCE, 2018 No. 9 OF 2018 Promulgated by the President in the Sixty-ninth Year of the Republic of India. An Ordinance further to amend the Companies Act, 2013. WHEREAS Parliament is not in session and the President is satisfi ed that circumstances exist which render it necessary for him to take immediate action; NOW, THEREFORE, in exercise of the powers conferred by clause (1) of article 123 of the Constitution, the President is pleased to promulgate the following Ordinance:- 1. (1) This Ordinance may be called the Companies (Amendment) Ordinance, 2018. Short title and commence- (2) It shall come into force at once. ment. 2. In section 2 of the Companies Act, 2013 (hereinafter referred to as the principal Amendment of Act), in clause (41),- section 2. (a) for the fi rst proviso, the following provisos shall be substituted, namely:- “Provided that where a company or body corporate, which is a holding company or a subsidiary or associate company of a company incorporated outside India and is required to follow a diff erent fi nancial year for consolidation of its accounts outside India, the Central Government may, on an application made by that company or body corporate in such form and manner as may be prescribed, allow any period as its fi nancial year, whether or not that period is a year: [ 1 ] 1-IV-4-12 TAMIL NADU GOVERNMENT GAZETTE [Part IV—Sec. 4 Provided further that any application pending before the Tribunal as on the date of commencement of the Companies (Amendment) Ordinance, 2018, shall be disposed of by the Tribunal in accordance with the provisions applicable to it before such commencement.”; (b) in the second proviso, for the words “Provided further that”, the words “Provided also that” shall be substituted. Insertion of new 3. After section 10 of the principal Act, the following section shall be inserted, section 10A. namely:- Commence- ment of “10A.(1) A company incorporated after the commencement of the Companies business, etc. (Amendment) Ordinance, 2018 and having a share capital shall not commence any business or exercise any borrowing powers unless- (a) a declaration is fl ied by a director within a period of one hundred and eighty days of the date of incorporation of the company in such form and verifi ed in such manner as may be prescribed, with the Registrar that every subscriber to the memorandum has paid the value of the shares agreed to be taken by him on the date of making of such declaration; and (b) the company has fl ied with the Registrar a verifi cation of its registered offi ce as provided in sub -section (2) of Section 12. (2) If any default is made in complying with the requirements of this section, the company shall be liable to a penalty of fi fty thousand rupees and every offi cer who is in default shall be liable to a penalty of one thousand rupees for each day during which such default continues but not exceeding an amount of one lakh rupees. (3) Where no declaration has been fi led with the Registrar under clause (a) of sub-section (1) within a period of one hundred and eighty days of the date of incorporation of the company and the Registrar has reasonable cause to believe that the company is not carrying on any business or operations, he may, without prejudice to the provisions of sub-section (2), initiate action for the removal of the name of the company from the register of companies under Chapter XVIII. Amendment of 4. In section 12 of the principal Act, after sub-section (8), the following sub-section section 12. shall be inserted, namely:- “(9) If the Registrar has reasonable cause to believe that the company is not carrying on any business or operations, he may cause a physical verifi cation of the registered offi ce of the company in such manner as may be prescribed and if any default is found to be made in complying with the requirements of sub-section (1), he may without prejudice to the provisions of sub-section (8), initiate action for the removal of the name of the company from the register of companies under Chapter XVIII.”. Amendment of 5. In section 14 of the principal Act,- section 14. (i) in sub-section (1), for the second proviso, the following provisos shall be substituted, namely:- “Provided further that any alteration having the eff ect of conversion of a public company into a private company shall not be valid unless it is approved by an order of the Central Government on an application made in such form and manner as may be prescribed: Provided also that any application pending before the Tribunal, as on the date of commencement of the Companies (Amendment) Ordinance, 2018, shall be disposed of by the Tribunal in accordance with the provisions applicable to it before such commencement.”; (ii) in sub-section (2), for the word “Tribunal”, the words “Central Government” shall be substituted. Amendment of 6. In Section 53 of the principal Act, for sub-section (3), the following sub-section shall section 53. be substituted, namely:- “(3) Where any company fails to comply with the provisions of this section, such company and every offi cer who is in default shall be liable to a penalty which may extend to an amount equal to the amount raised through the issue of shares a discount or fi ve lakh rupees, whichever is less, and the company shall also be liable to refund all monies received with interest at the rate of twelve per cent. per annum from the date of issue of such shares to the persons to whom such shares have been issued.”.Jan. 2, 2019] TAMIL NADU GOVERNMENT GAZETTE 3 7. In section 64 of the principal Act, for sub-section (2), the following sub-section shall Amendment of be substituted, namely:- section 64. “(2) Where any company fails to comply with the provisions of sub-section (1), such company and every offi cer who is in default shall be liable to a penalty of one thousand rupees for each day during which such default continues, or fi ve lakh rupees whichever is less.”. 8. In section 77 of the principal Act, in sub-section (1), for the fi rst and second provisos, Amendment of the following provisos shall be substituted, namely:- section 77. “Provided that the Registrar may, on an application by the company, allow such registration to be made- (a) in case of charges created before the commencement of the Companies (Amendment) Ordinance, 2018, within a period of three hundred days of such creation; or (b) in case of charges created on or after the commencement of the Companies (Amendment) Ordinance, 2018, within a period of sixty days of such creation, on payment of such additional fees as may be prescribed: Provided further that if the registration is not made within the period specifi ed- (a) in clause (a) to the fi rst proviso, the registration of the charge shall. be made within six months from the date of commencement of the Companies (Amendment) Ordinance, 2018, on payment of such additional fees as may be prescribed and diff erent fees may be prescribed for diff erent classes of companies; (b) in clause (b) to the fi rst proviso, the Registrar may, on an application, allow such registration to be made within a further period of sixty days after payment of such advalorem fees as may be prescribed.”. 9. Section 86 of the principal Act shall be numbered as sub-section (1) thereof and Amendment of after sub-section (1) as so numbered, the following sub-section shall be inserted, namely:- section 86. “(2) If any person wilfully furnishes any false or incorrect information or knowingly suppresses any material information, required to be registered in accordance with the provisions of Section 77, he shall be liable for action under section 447.”. Substitution of 10. For Section 87 of the principal Act, the following section shall be substituted, new section namely:- for section 87. Rectifi cation “87. The Central Government on being satisfi ed that - by Central Government in Register of charges. (a) the omission to give intimation to the Registrar of the payment or satisfaction of a charge, within the time required under this Chapter; or (b) the omission or misstatement of any particulars with respect to any such charge or modifi cation or with respect to any memorandum of satisfaction or other entry made in pursuance of Section 82 or Section 83, was accidental or due to inadvertence or some other suffi cient cause or it is not of a nature to prejudice the position of creditors or shareholders of the company, it may, on the application of the company or any person interested and on such terms and conditions as the Central Government deems just and expedient, direct that the time for the giving of intimation of payment or satisfaction shall be extended or, as the case may require, that the omission or misstatement shall be rectifi ed.”. 11. In section 90 of the principal Act,- Amendment of section 90. (i) for sub-section (9), the following sub-section shall be substituted, namely:- “(9) The company or the person aggrieved by the order of the Tribunal may make an application to the Tribunal for relaxation or lifting of the restrictions placed under sub-section (8), within a period of one year from the date of such order:4 TAMIL NADU GOVERNMENT GAZETTE [Part IV—Sec. 4 Provided that if no such application has been fi led within a period of one year from the date of the order under sub-section (8), such shares shall be transferred to the authority constituted under sub-section (5) of section 125, in such manner as may be prescribed; (ii) in sub-section (10),- (a) after the word “punishable”, the words “with imprisonment for a term which may extend to one year or” shall be inserted; (b) after the words “ten lakh rupees”, the words “or with both” shall be inserted. Amendment of 12. In section 92 of the principal Act, for sub-section (5), the following sub-section shall section 92. be substituted, namely:- “(5) If any company fails to fi le its annual return under sub-section (4), before the expiry of the period specifi ed therein, such company and its every offi cer who is in default shall be liable to a penalty of fi fty thousand rupees and in case of continuing failure, with further penalty of one hundred rupees for each day during which such failure continues, subject to a maximum of fi ve lakh rupees.”. Amendment of 13. In section 102 of the principal Act, for sub-section (5), the following sub-section shall section 102. be substituted, namely:- “(5) Without prejudice to the provisions of sub-section (4), if any default is made in complying with the provisions of this section, every promoter, director, manager or other key managerial personnel of the company who is in default shall be liable to a penalty of fi fty thousand rupees or fi ve times the amount of benefi t accruing to the promoter, director, manager or other key managerial personnel or any of his relatives, whichever is higher.”. Amendment of 14. In section 105 of the principal Act, in sub-section (3), for the words “punishable with section 105. fi ne which may extend to fi ve thousand rupees”, the words “liable to a penalty of fi ve thousand rupees” shall be substituted. Amendment of 15. In section 117 of the principal Act, for sub-section (2), the following sub-section shall section 117. be substituted, namely:- “(2) If any company fails to fi le the resolution or the agreement under sub-section (1) before the expiry of the period specifi ed therein, such company shall be liable to a penalty of one lakh rupees and in case of continuing failure, with further penalty of fi ve hundred rupees for each day after the fi rst during which such failure continues, subject to a maximum of twenty-fi ve lakh rupees and every offi cer of the company who is in default including liquidator of the company, if any, shall be liable to a penalty of fi fty thousand rupees and in case of continuing failure, with further penalty of fi ve hundred rupees for each day after the fi rst during which such failure continues, subject to a maximum of fi ve lakh rupees.”. Amendment of 16. In section 121 of the principal Act, for sub-section (3), the following sub-section section 121. shall be substituted, namely:- “(3) If the company fails to fi le the report under sub-section (2) before the expiry of the period specifi ed therein, such company shall be liable to a penalty of one lakh rupees and in case of continuing failure, with further penalty of fi ve hundred rupees for each day after the fi rst during which such failure continues, subject to a maximum of fi ve lakh rupees and every offi cer of the company who is in default shall be liable to a penalty which shall not be less than twenty-fi ve thousand rupees and in case of continuing failure, with further penalty of fi ve hundred rupees for each day after the fi rst during which such failure continues, subject to a maximum of one lakh rupees.”. Amendment of 17. In section 137 of the principal Act, in sub-section (3),- section 137. (a) for the words “punishable with fi ne”, the words “liable to a penalty” shall be substituted; (b) for the words “punishable with imprisonment for a term which may extend to six months or with fi ne which shall not be less than one lakh rupees but which may extend to fi ve lakh rupees or with both”, the words “shall be liable to a penalty of one lakh rupees and in case of continuing failure, with further penalty of one hundred rupees for each day after the fi rst during which such failure continues, subject to a maximum of fi ve lakh rupees” shall be substituted.Jan. 2, 2019] TAMIL NADU GOVERNMENT GAZETTE 5 18. In section 140 of the principal Act, for sub-section (3), the following sub-section shall Amendment be substituted, namely:- of section 140. “(3) If the auditor does not comply with the provisions of sub-section (2), he or it shall be liable to a penalty of fi fty thousand rupees or an amount equal to the remuneration of the auditor, whichever is less, and in case of continuing failure, with further penalty of fi ve hundred rupees for each day after the fi rst during which such failure continues, subject to a maximum of fi ve lakh rupees.”. 19. In section 157 of the principal Act, for sub-section (2), the following sub-section shall Amendment of be substituted, namely:- section 157. “(2) If any company fails to furnish the Director Identifi cation Number under sub-section (1), such company shall be liable to a penalty of twenty-fi ve thousand rupees and in case of continuing failure, with further penalty of one hundred rupees for each day after the fi rst during which such failure continues, subject to a maximum of one lakh rupees, and every offi cer of the company who is in default shall be liable to a penalty of not less than twenty-fi ve thousand rupees and in case of continuing failure, with further penalty of one hundred rupees for each day after the fi rst during which such failure continues, subject to a maximum of one lakh rupees.”. 20. For section 159 of the principal Act, the following section shall be substituted, Substitution of namely:- new section for section 159. “159. If any individual or director of a company makes any default in complying with Penalty for any of the provisions of section 152, section 155 and section 156, such individual or director of default the company shall be liable to a penalty which may extend to fi fty thousand rupees and where of certain the default is a continuing one, with a further penalty which may extend to fi ve hundred rupees provisions. for each day after the fi rst during which such default continues.”. 21. In section 164 of the principal Act, in sub-section (1), after clause (h), the following Amendment of clause shall be inserted, namely:- section 164. “(i) he has not complied with the provisions of sub -section (1) of section 165.”. 22. In section 165 of the principal Act, in sub-section (6), for the portion beginning with Amendment of “punishable with fi ne” and ending with “contravention continues”, the words “liable to a penalty section 165. of fi ve thousand rupees for each day after the fi rst during which such contravention continues” shall be substituted. 23. In section 191 of the principal Act, for sub-section (5), the following sub-section shall Amendment of be substituted, namely:- section 191. “(5) If a director of the company makes any default in complying with the provisions of this section, such director shall be liable to a penalty of one lakh rupees.”. Amendment of 24. In section 197 of the principal Act,- section 197. (a) sub-section (7) shall be omitted; (b) for sub-section (15), the following sub-section shall be substituted, namely:- “(15) If any person makes any default in complying with the provisions of this section, he shall be liable to a penalty of one lakh rupees and where any default has been made by a company, the company shall be liable to a penalty of fi ve lakh rupees.”. 25. In section 203 of the principal Act, for sub-section (5), the following sub-section shall Amendment of be substituted, namely:- section 203. “(5) If any company makes any default in complying with the provisions of this section, such company shall be liable to a penalty of fi ve lakh rupees and every director and key managerial personnel of the company who is in default shall be liable to a penalty of fi fty thousand rupees and where the default is a continuing one, with a further penalty of one thousand rupees for each day after the fi rst during which such default continues but not exceeding fi ve lakh rupees.”.6 TAMIL NADU GOVERNMENT GAZETTE [Part IV—Sec. 4 Amendment of 26. In section 238 of the principal Act, in sub-section (3), for the words “punishable with section 238. fi ne which shall not be less than twenty-fi ve thousand rupees but which may extend to fi ve lakh rupees”, the words “liable to a penalty of one lakh rupees” shall be substituted. Amendment of 27. In section 248 of the principal Act, in sub-section (1),- section 248. (a) in clause (c), for the word and fi gures “section 455,”, the words and fi gures “section 455; or” shall be substituted; (b) after clause (c) and before the long line, the following clauses shall be inserted, namely:- “(d) the subscribers to the memorandum have not paid the subscription which they had undertaken to pay at the time of incorporation of a company and a declaration to this eff ect has not been fi led within one hundred and eighty days of its incorporation under sub -section (1) of section 10A; or (e) the company is not carrying on any business or operations, as revealed after the physical verifi cation carried out under sub-section (9) of section 12.”. Amendment of 28. In section 441 of the principal Act,- section 441. (a) in sub-section (1), in clause (b), for the words “does not exceed fi ve lakh rupees”, the words “does not exceed twenty-fi ve lakh rupees” shall be substituted; (b) for sub-section (6), the following sub-section shall be substituted, namely:- “(6) Notwithstanding anything contained in the Code of Criminal Procedure, 1973, any off ence which is punishable under this Act with imprisonment only or with 2 of 1974. imprisonment and also with fi ne shall not be compoundable.”. Amendment of 29. In section 446B of the principal Act, for the portion beginning with “punishable with section 446B. fi ne” and ending with “specifi ed in such sections”, the words “liable to a penalty which shall not be more than one half of the penalty specifi ed in such sections” shall be substituted. Amendment of section 447. 30. In section 447 of the principal Act, in the second proviso, for the words ‘’twenty lakh rupees”, the words “fi fty lakh rupees” shall be substituted. Amendment of section 454. 31. In section 454 of the principal Act,- (i) for sub-section (3), the following sub-section shall be substituted, namely: - “(3) The adjudicating offi cer may, by an order- (a) impose the penalty on the company, the offi cer who is in default, or any other person, as the case may be, stating therein any non-compliance or default under the relevant provisions of this Act; and (b) direct such company, or offi cer who is in default, or any other person, as the case may be, to rectify the default, wherever he considers fi t.”; (ii) in sub-section (8), - (a) in clause (i), for the words “does not pay the penalty imposed by the adjudicating offi cer or the Regional Director”, the words, brackets and fi gures “fails to comply with the order made under sub-section (3) or sub-section (7), as the case may be,” shall be substituted; (b) in clause (ii), for the words “does not pay the penalty”, the words, brackets and fi gures “fails to comply with the order made under sub-section (3) or sub-section (7), as the case may be,” shall be substituted.Jan. 2, 2019] TAMIL NADU GOVERNMENT GAZETTE 7 32. After section 454 of the principal Act, the following section shall be inserted, Insertion of a namely:- new section 454A. “454A. Where a company or an offi cer of a company or any other person having Penalty for already been subjected to penalty for default under any provisions of this Act, again commits repeated such default within a period of three years from the date of order imposing such penalty default passed by the adjudicating offi cer or the Regional Director, as the case may be, it or he shall be liable for the second or subsequent defaults for an amount equal to twice the amount of penalty provided for such default under the relevant provisions of this Act.”. R(cid:3465)(cid:3477) N(cid:3465)(cid:3484)(cid:3472) K(cid:3479)(cid:3486)(cid:3473)(cid:3478)(cid:3468), President. D(cid:3482). G. N(cid:3465)(cid:3482)(cid:3465)(cid:3489)(cid:3465)(cid:3478)(cid:3465) R(cid:3465)(cid:3474)(cid:3485), Secretary to the Government of India. (Re-published by Order of the Governor) K. RAVIKUMAR, Additional Secretary to Government, Law Department. PRINTED AND PUBLISHED BY THE DIRECTOR OF STATIONERY AND PRINTING, CHENNAI ON BEHALF OF THE GOVERNMENT OF TAMIL NADU

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