Time frame within which fc-gpr is to be filed

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Akshat Bansal (Querist)
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22 August 2014 Dear Sir/Ma'am,
I have a non resident client (USA) whose company was incorporated on 25/07/2014. Foreign Remittance was received on 05/08/2014 and Board Resolution for signing Share Certificates was passed on 21/08/2014. As per Circular No. 15/2011-12 of RBI, details of the receipt of the amount of consideration should be reported within 30 days after which Unique Identification Number (UIN) will be allotted. Also in the above circular it is also mentioned that FC-GPR should be filed within 30 days from the allotment of shares.

My query is whether the date of allotment will be date of incorporation or the date on which foreign remittance was received or the date on which share certificates were signed since we had already shown Rs 10,00,000 paid up capital at the time of incorporation. Bank A/c had to be opened after receiving Certificate of Incorporation and therefore foreign funds were received after date of Incorporation. If date of incorporation is treated as date of allotment then the Last date of filing FC-GPR will be 24/08/2014 while UIN is still not alloted.

Kindly provide a solution as soon as possible.

Thank you in Advance.

CA Kedar Sakhardande