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277 / 2022



Quote of the day

"Yoga teaches us to cure what need not be endured and endure what cannot be cured."

- B.K.S.Iyengar

  • Have you ever played Snake & Ladder ? Can you recall the joy of casting the dice and getting started ? the thrill of climbing multiple ladders ? the disappointment of being bitten by a snake ? the frustration of being pushed back to the bottom of the board when you almost thought you had made it ? the double-joy of seeing someone lose ? The highs and lows of this simple game marked by unexpected twists and turns is what that makes it so exciting and enjoyable.

Now why am I talking of this bygone era game in this digital times ?

Because we professionals are forced into playing this game day in and day out on the MCA (Ministry of Corporate Affairs) portal !! Read on…..

  • Did you know that the elephant has a gestation period longer than any living mammal ? 680 days of pregnancy which is believed to make them strong and intelligent.

Now, why am I talking of the pachyderm’s pregnancy ? Is it to mark World Environment Day on 5th June ? No. Because startup founders are getting impatient with the ‘oh-so-long-pregnant’ MCA which hasn’t been able to deliver their LLPs on time 😊

  • ˙ʎɐp ɐƃoʎ ʎddɐɥ ˙ʍou ɐuɐsɹǝǝɥs ƃuᴉop ɯɐ I ˙ƃuᴉuɹoɯ pooפ 🙃

Now, why am I talking of this difficult inverted body pose (Shirasasana) ? Is it to celebrate World Yoga Day on 21st June or showcase our agility on PCS Day, 15th June? Neither.

Because even if we stand upside down as the last resort for beseeching MCA, it doesn’t seem to work ! You do need yogic patience and saintly qualities to tame your ‘rogue elephantisque temper’ and not get frustrated, servicing clients who seek simple service of setting up an LLP (:

  • Do you play Antakshari (a game of songs) during office hours ?

Now why am I talking crazily out of my head ? Is it to enjoy World Music Day on 21st June ? Not at all.

Because music is the best stress-buster when you are caught in a helpless situation, unable to deliver the promised service due to technical glitches of a portal which routinely closes tickets, leaving the issue unresolved !!

Enough of ranting. Let me GET TO THE POINT ! Bound by our professional code of conduct, we cannot rave and rant like aam janata on social media about the LLP V3 portal of MCA. It doesn’t serve any purpose. We do believe that our alma mater ICSI is doing what best it can to get our grievances redressed by the MCA. However, I cannot stop myself from sharing the LLP-saga, penned as below by two of my young ‘unmarried colleagues’ (Rajeswari & Anjali) who are experiencing ‘birthing-pangs’ trying to incorporate LLPs since March, 2022 😊

Patience is not the ability to wait but the ability to keep a good attitude while waiting.” -Joyce Meyer. The whole incorporation experience in the new regime will test your patience and will. In the month of March 2022, we got a proposal for incorporation of two Limited Liability Partnership (LLPs), which were to further set up an entity abroad (under ODI regulations) within a specific timeframe. Based on our previous experience, we advised the clients about the process, documents and timelines involved. Little did we know that the timeline for incorporation would get dragged from 2 weeks to 3 months solely on account of technical glitches.

Out of the 2 LLPs, one got incorporated without much hassle although there were prefill issues in the initial days. However, the second LLP was struck by a lightning of endless issues and was ultimately abandoned by the client.

  • 16th March, 2022 - Application for reservation of name was filed. Challan was not getting generated. Status of SRN was appearing as ‘invalid SRN’.

  • 24th March – Approval email received but no approval letter attached. Application history still showed the SRN status as ‘Under Processing’. Unable to proceed with the incorporation of LLP for 2 weeks.

  • 7th April – issue resolved after escalation through multiple tickets and emails.

  • Strange problems continued - No options to select appropriate district for DIN of DPs. District prefilled based on PIN Code showed an error stating ‘enter alphanumeric values’.

  • Forms marked for resubmission even when the documents were in order. Unable to resubmit within time due to portal issues.

  • For days, tickets went unresolved or were simply closed as ‘resolved’ by technical team.

The entire team tried coming up with innovative ideas to tackle this frustrating situation. As the saying goes Frustration is the fuel that can lead to the development of an innovative and useful idea. - Marley Dias.

  • Convinced the client to start the incorporation process afresh. But besieged with fresh technical problems related to identity proofs of the DPs, SRN of previously filed FiLLiP form still open though the validity had expired.

  • Tried with innovative, alternative ID proofs but came back for resubmission, requiring something that was already attached.

  • Being a time sensitive matter due to the ODI aspects involved, clients finally decided to abandon the birthing of second LLP and alter the structure of existing LLP.

  • Again the V3 portal played spoil sport - due to the differences in the version of portal, a simple form for application for DIN could not be filed.

  • The last turn that we took was to incorporate a company and then using the same DIN, onboard the director as a DP in the existing LLP. This hasn’t helped much either - the LLP agreement cannot be amended now since the original one is still pending approval for more than 3 weeks ! Doesn’t it fell like a stone stuck in the neck of a bottle ?

It is like climbing a ladder one day but sliding down several on the next, bitten by the proverbial snake !!

I am sure thousands of professionals have similar saga to share. I wish and pray and hope that the trade bodies and industry chambers take up the matter with the government because it is not just filing some forms and setting up an entity. It is loss of productive hours, money, opportunities and credibility resulting in huge economic loss.

While uncertainty is galore on the MCA portal despite (or ironically because of !) its huge technology backing, there is no uncertainty about Samhita’s arrival every month (for the longest years it was fortnightly). Here’s the 277th issue with the regular players (read regulatory updates). Don’t miss out on the tips on Usage of Prepositions by Balaji, author of the ‘Let’s excel in English’ feature. For any previous issues of Samhita and the readers’ feedback, please visit http://www.sharadasc.com/resource-center/.

Happy Reading,

S.C. Sharada


Prepositions are one of the trickiest parts of the English language. One may take forever to master it though these are usually monosyllabic words.

Tip 1:

*For* or *To*

In most cases, if a word has both noun form and an adjective verb form, 'For' is used before the 'noun' and 'To' is used before the 'verb'


“Tips to excel in English”

“Centre for excellence in English “

(On the contrary, we do have some cases places where 'of' is used instead of 'to' in some cases and the debate may go on forever)

Tip 2:

Charter of Audit Committee or Charter for Audit Committee ?

Should it be 'of' or 'for' which is the correct collocation ?

If we consider what preposition is used between two nouns, the 'of' comes to our mind first because of the renowned usages like 'Branches of the bank', 'Centre of excellence'.

The question that arises immediately is 'Centre of excellence' and 'Centre for research' are also widely used and are correct usages.

Well, can we say that 'of' can be replaced by 'for' in all such examples ? Not really. We hardly say 'branches for the bank'. So, they're not obviously interchangeable.

However when the preposition is used to refer to a purpose, 'for' can be used at places where 'of' is used before two nouns.

Well , English brings more exceptions- Let's take the term,

'Institute of Science and Technology'. Though, we hardly use 'for' in such

cases, it's not incorrect.

Charter of Audit Committee or Charter for Audit Committee ? - It can be both

Following are the research links for Oxford Collocation Dictionary:



Tip 3:

Where should we not use prepositions?

1. After the words, 'discuss', 'near', 'describe', 'tell'

We will discuss the project today.

My house is near the temple.

He described every detail of the painting.

I have told them that it's really important.

2. Before the word 'home'

I go home at 6 PM every evening.

3. When the word 'go' is used with gerunds ('ing' from of a verb which is used as a noun- example: swimming)

I go swimming

She goes cycling

I went shopping

How could you know if a preposition can be used with another word or not?

Google 'Prepositions that collocate with <noun/verb>'

Balaji Ramaswamy N
Mobile: 9741393539

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Reminders for Payments & Returns

Regulatory Updates

MCA Updates

Security clearance required for appointment of Director or for DIN application

MCA vide notification dated 01.06.2022, notified the Companies (Appointment and Qualification of Directors) Amendment Rules, 2022. The changes brought about by the Amendment Rules are as follows:

  • A person who is a national of a country sharing land borders with India is required to obtain security clearance from the Ministry of Home Affairs to obtain DIN and to be eligible to be appointed as a director.

  • In Form DIR-2 (Consent to act as director) and Form DIR-3 (DIN application) the proposed director / DIN holder should declare that:

    • He is not required to obtain security clearance, or

    • That necessary security clearance has been obtained and the same has been attached to the form being filed.

Open Notification No. G.S.R. 410(E) dtd.01.06.2022

One more resubmission available for Form STK-2

MCA vide notification dated 09.06.2022, has notified that companies that have filed form STK-2 for voluntary strike off will now be allowed 2 resubmissions if the Registrar finds the form defective. The form shall be resubmitted within 15days of receipt of resubmission remarks.

Earlier only 1 resubmission was allowed for Form STK-2.

Open Notification No. G.S.R. 436(E) dtd.09.06.2022

Restoration of name in ID Data Bank

Independent Directors (ID) whose names have been included in the Databank are required to clear an online proficiency test within 2 years of inclusion of their name in the Databank, failing which their names shall be removed from the Databank.

Vide notification dated 10.06.2022, a sub-rule has been inserted, allowing restoration of name of any individual whose name has been removed from the Databank, provided they clear the online proficiency self-assessment test within 1 year of restoration. Failing this, the individual will have to file a fresh application.

Open Notification No. G.S.R. 439(E) dtd.10.06.2022

No additional fees for event based LLP Forms and LLP Form 11

  • Considering the technical difficulties faced by stakeholders and based on the representations received, MCA vide circular dated 31.05.2022, has exempted the liability of additional fee on LLPs upto 30.06.2022 for the event based filings which were due during the period 25.02.2022 – 31.05.2022.

  • MCA vide Circular dated 29.06.2022 has relaxed the levy of additional fee on LLP Form 11 (Annual Return) till 15.07.2022.

Open General Circular No. 06/2022 dtd.31.05.2022

Open General Circular No. 07/2022 dtd.29.06.2022

No additional fees for LLP Forms with due date 25.02.2022 – 31.05.2022

Considering the technical difficulties faced by stakeholders and based on the representations received, MCA vide circular dated 31.05.2022, has exempted the liability of additional fee on LLPs upto 30.06.2022 for the event based filings which were due during the period 25.02.2022 – 31.05.2022.

Open General Circular No. 06/2022 dtd.31.05.2022

Due date for filing Form CSR-2 – extended upto 30.06.2022

MCA vide notification dated 31.05.2022, has extended the due date for filing Form CSR-2 from 31.05.2022 to 30.06.2022.

The notification also inserted another proviso under Rule 12(1B) of the Companies (Accounts) Rules, 2014, which states that Form CSR-2 for the FY 2021-22 shall be filed after filing of Form AOC-4/AOC-4 XBRL/AOC-4 NBFC (Ind AS), by 31.03.2023.

Open Notification No. G.S.R.407(E) dtd.31.05.2022

RBI Updates

Restriction on storage of actual card data - timeline extended

RBI vide its Circular dated 17.03.2020 had imposed prohibition on storage of card data (COF) by the authorised non bank payment aggregators and merchants on-boarded by them from 30.06.2021 and upon receipt of various representations, the same was extended to 31.12.2021 and subsequently extended to 30.06.2022 vide RBI circular dated 23.12.2021.

The same has been further extended till 30.09.2022 vide RBI circular dated 24.06.2022, after which the data shall be purged.

RBI permitted Card on File Tokenisation vide its Circular dated 07.09.2021. Under this mechanism of tokenisation, the sensitive card data would be replaced by random numbers. In the RBI circular dated 23.12.2021 RBI had further clarified that industry stakeholders may use any other mechanism in addition to tokenisation for transactions that currently involve/requires storage of card data.

Open Notification No. RBI/2022-23/77 dtd.24.06.2022

Discontinuation of return on details of guarantee availed and invoked from non-resident entities

AD Banks were advised earlier in the year vide circular no.26 dtd.18.02.2022 about the proposed discontinuation of return on “Details of guarantee availed and invoked from non-resident entities”. The return was to be filed for issue and invoking of non-resident guarantee for fund based and non-fund based facilities (such as Letters of Credit/guarantees etc.) availed by one resident from another in India. The above return shall be discontinued w.e.f. quarter ending June 22.

Open Notification No. RBI/2022-23/69 dtd.09.06.2022

IBBI Updates

Complaint handling procedure – amended

  • To streamline the grievance handling procedure, IBBI has notified the IBBI (Grievance and Complaint Handling Procedure) (Amendment) Regulations, 2022 and IBBI (Inspection and Investigation) (Amendment) Regulations, 2022. IBC and these Regulations offer a mechanism for redressal of complaints against IPs, IPAs and Insolvency Utilities (IU). Highlights of the changes as per the Press Release are as follows:

  • Timelines related to enforcement processes have been revised

  • Effective participation of IPAs in regulating the IPs through examination of grievances received against IPs.

  • Intimation to Committee of Creditor (CoC)/ Adjudicating Authority (AA) about the outcome of Disciplinary Committee (DC) order.

The Amendment Regulations are effective from 14.06.2022.

Open Notification No. IBBI/2022-23/GN/REG086 dtd.14.06.2022

Open Notification No. IBBI/2022-23/GN/REG087 dtd.14.06.2022

Open Press Release

GST Updates

Late fee waived for Form GSTR4

CBIC vide notification dated 26.05.2022 seeks to waive the late fee under section 47 for the period from 01.05.2022 till 30.06.2022 for delay in filing Form GSTR4.

Open Notification No. 07/2022 dtd.27.05.2022

Income Tax Updates

Cost inflation index for FY 22-23 notified

CBDT has notified the cost inflation index for the Financial Year 2022-23 as 331, vide Notification dated 14.06.2022.

Open Notification No. 62/2022 dtd.14.06.2022

Clarification on Form 10AC

CBDT has issued clarification regarding Form No 10ACs issued in the past. It is clarified that where due to technical glitches, Form No. 10AC has been issued during FY 2021- 2022 with the heading “Order for provisional registration” or “Order for provisional approval” instead of “Order for registration” or “Order for approval”, then all such Form No. 10AC shall be considered as an “Order for registration or approval”.

Open Circular No. 11/2022 dated 03.06.2022

Note: The contents of this Newsletter are only a summary and has not dealt with any issue in detail. Any action taken or proposed to be taken must be in consultation with professionals and not merely based on the articles / news updates. S. C. Sharada & Associates disclaims all liability on action taken without professional advice.