

DPT-3 Mandatory Information of all Loans to ROC
Mandatory Filing of Details of Loan with ROC in brief with some important FAQ’s in relation to DPT-3 with reference to Companies (Acceptance of Deposits) Amendment Rules, 2019 notified by MCA on 22.01.2019.
By Companies (Acceptance of Deposits) Amendment Rules, 2019 : Every Company other than Government Company shall file a onetime return of outstanding receipt of money or loan by a company but not considered as deposits, in term of clause (c) of sub-rule 1 of rule 2 from the 01st April, 2014 to the date of publication of this notification in the official Gazette (i.e. 22nd January, 2019) in e-form DPT-3 within 90 days from the date of publication.”.
All the Companies (Whether, Small, Non-Small, Private, Public, OPC, etc.) required to file DPT-3 after publication of these rules.
Due date of Filing of e-form DPT-3 in rule 16A is 22nd April, 2019. Because form required to file within 90 days of publication of these rules. (22nd January, 2019 + 90 days)
Yes, DPT-3 required for filing for both secured and unsecured Loan.
As per rule 16A DPT-3 required to file for each and every loan received by Company. Therefore, one can opine that if Company has received ECB in such case Company have to mandatorily file e-form DPT-3.
Outstanding receipt of Money and Loan from 1st April, 2014 to 22nd January, 2019 (i.e. date of publication of notice) is required to report in e-form DPT-3..
As per rule 16A DPT-3 required to file for each and every loan received by Company. Therefore, Company required to file e-form DPT-3 even for loan received from H,S and Associate.
As per rule 16A DPT-3 Every Company other than Government Company shall file a onetime return of outstanding receipt of money or loan by a company but not considered as deposits.
Therefore, one can opine that in the above-mentioned situation there is no need to file e-form DPT-3.
As per rule 16A DPT-3 required to file for each and every loan received by Company outstanding as on date of publication of these rules (22.01.2019).
Therefore, one can opine that such outstanding loan is required to report to ROC in e-form DPT-3.
As per language of Rule 16A, company has to report outstanding Loan and outstanding receipt of money to Roc in DPT-3. If Company has already paid Loan and such loan is not outstanding in record of Company. There is no need to inform such loan to ROC.
If there is no outstanding Loan or company doesn’t accept any loan there is no need to file e-form DPT-3 with ROC.
Regards