07 February 2012
Dear members, Our client co.filed 2 fc-gpr for its first subscription amount of rs 1.50lacs at two diffrent dates through FIRC dated 5/07/11 n 15/07/11 (issued by 2 diffrnt banks)and also alloted it at 2 dates by resolution dated 05/08/2011 n 11/08/11.nw rbi hv sent notice to d compny statng that being d subscriptn amount it cnnot b alloted at 2 different dates n only one fcgpr need 2 b filed with rbi. My query is "is there any cirular or notification statng dat subscriptn amount cannot b alloted partly or any other circular related to the same.
I think you have filed the Advance Reporting Form with RBI within 30 days from the date of received of consideration. Indian company also required to report the details of receipt of amount of consideration for issue of shares through an AD Bank together with FIRC along with KYC report.
In your case, you have received total subscription amount in two tranche and you allotted shares on two dates. If you have filed two FC-GPR with RBI, have you attached necessary certificate like PCS certificate for compliance of Companies Act, 1956 of different dates or not.
As such there is no notification from RBI on your matter that you can not file two FC-GPR with RBI.
11 February 2012
Although amount received on different dates but whether allotment was done once or twice? If once then only fc gpr needs to be submitted. Cavishalshah@gmail.com
CAclubindia
