Complete Details explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
A disclosure requirement is only as strong as its two weakest phrases. Here both are defined — and defined so that neither an unnamed party nor an unwritten arrangement escapes.
What "complete details" means
The term "complete details" used at various places would mean that details of each particular party / entity should include:
| Element | Purpose |
|---|---|
| The name | Identifies the party |
| The registered address | Locates it, including outside India |
| Any government identification number — for example PAN, SSN, CIN | Makes the identification verifiable against a public register |
| The relationship with the company making the disclosure | Shows whether the counterparty is connected to the company |
The inclusion of SSN alongside PAN and CIN is a small but telling detail — the definition anticipates foreign parties, consistent with the disclosure's repeated reference to including foreign entities.
The disclosure is triggered by an understanding "whether recorded in writing or otherwise". Without a definition, that phrase would be unusable — a company could simply say no agreement existed.
The Guidance Note supplies one: the phrase shall be construed on the basis of appropriate evidences, for example board or shareholder resolutions, investment agreements, share purchase agreements, term sheets, or any other relevant / appropriate documents evidencing such an understanding either specifically in writing or otherwise (i.e. not specifically but through the objective / understanding of the overall transaction / flow of funds).
Two routes, then. The first is documentary — resolutions, agreements, term sheets. The second is inferential: the objective of the overall transaction and the flow of funds themselves.
The second route is what makes the requirement operative. Where money arrives from a party and leaves within days to a recipient that party would obviously benefit, the flow of funds is itself the evidence — no document has to be produced for the disclosure to apply.
Which parties need complete details
- Each Intermediary to whom funds were advanced, loaned or invested;
- Each Funding Party from whom funds were received;
- Each of the other intermediaries or ultimate beneficiaries in the onward flow.
The requirement therefore extends to parties with which the reporting company may have no direct relationship at all — which is why the definition ends with relationship with the company making the disclosure rather than assuming one exists.
The transitional relief
For the purpose of this disclosure, the company may restrict to disclose only the pass-through transactions during the current year, i.e. for the funds received on or after 01.04.2021 and the amounts unutilized as on 01.04.2021 which are now utilized in the current year.
The relief is narrower than it first appears. It does not exempt older money outright — funds that were sitting unutilised on 1 April 2021 and are deployed in the current year come back into the disclosure at the point of deployment.
In the consolidated financial statements
Utilization of borrowed funds and share premium shall be provided at CFS level after applying principles of consolidation — i.e. this disclosure would be for funds borrowed or invested outside the group. However, it shall be disclosed only if material, i.e. more than 10% of the respective financial statement line item in the CFS.
Common mistakes
- Naming parties without address, identification number and relationship.
- Denying an understanding because no written agreement exists.
- Treating pre-April 2021 balances as permanently outside the disclosure.
- Including intra-group flows in the consolidated disclosure.