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The deadline for companies to file Form INC 22A is April 25, 2019. There is no fee charged if the form is filed within the due date; however, in case of delay, a penalty of Rs 10,000 is applicable. However, the Ministry of Corporate Affairs (MCA) is considering extending the deadline, based on the representations received from the industry associates, including startups.
The MCA introduced Form INC 22A for validating the addresses of all the registered companies under the Companies Act, 2013. The form goes by the name tag ACTIVE (Active Company Tagging Identities and Verification). All the registered companies are required to upload a photo of the external and the internal premises of their registered offices along with the photo of one director, the one who signs the form. The photo of the external premises must display the nameplate, including CIN, registered address, e-mail and phone numbers.
The representations made by the industry associations are one of the reasons for MCA to consider the extension of the deadline. The startups, in particular, were mostly riled up about the compliance with these norms, that came soon after the resolution of the angel tax issue.
A lot of startups share office space or operate out of homes of their directors. Hence, the impracticality of putting company board on such places is a big bother for startups.
It will be difficult for companies to make the required changes in their share capital structure. It will also be difficult to go ahead with amalgamation and merger deals if they do not comply with such norms.
Thus, the MCA is considering extending the deadline for filing of Form INC 22A, keeping in mind the impracticality for some startups.
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