29 April 2019
If some person is holding DIN and wants to surrender it, he cannot surrender as he is not falling under 4-5 reasons for surrender of DIN.
30 April 2019
Yes, you are absolutely right. Many persons applied and got DIN due to various reasons but they are not a a Director in any Company or Partner in LLP. Still they are compulsorily required to file KYCs etc. MCA must allow people to surrender their DIN if they do not require it anymore/not used it earlier.