Section 185 under companies act, 2013

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CMA Sachin Warat (Querist)
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13 February 2016 Dear Sir,

MCA has exempted private companies from compliance with provisions of section 185 of Companies Act, 2013. Subject to fulfilment of three conditions :

1) no body should be member of a private company

2) the "borrowings" of such private company should not exceed twice of its paid up capital or 50 Crore whichever is lower,

3) private company should not make any default in repayment of loans.

Whether in condition no. 2 above the word "borrowings" means total borrowing including term loans and working capital or only term loan ????

Kindly give clarification on this points.

Regards,
Sachin