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Ordinary Course Exemption Under Section 188 and the Subsidiary Carve-Out

Two categories of related party transaction escape shareholder approval — the arm's length trade, and the deal with a wholly owned subsidiary whose accounts are consolidated.

Vikas Sharma Tax & Compliance Expert
4 min read 6 views Updated Sep 9, 2026 Expert Reviewed High Complexity
Ordinary Course Exemption Under Section 188 and the Subsidiary Carve-Out
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Last updated: September 2026Verified against: Government sources
Quick Answer

Two categories of related party transaction escape shareholder approval — the arm's length trade, and the deal with a wholly owned subsidiary whose accounts are consolidated.

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What is exempt

As per Section 188(1) of the CA, 2013, following transactions do not require approval of the shareholders under Section 188 of the CA, 2013:

  • Transactions in ordinary course of business and on arm's length basis;
  • Transactions between holding company and wholly owned subsidiary company whose accounts are consolidated and laid before shareholders at AGM.
Why the ordinary course exemption needs both limbs, and what each one catches on its own

Section 188 exists because a related party transaction is negotiated by people who may be on both sides of it. The exemption identifies transactions where that concern does not arise — and it takes two conditions to get there, because either alone leaves a gap.

Ordinary course of business, but not at arm's length. A company that sells cement sells cement to a director's firm. The activity is entirely ordinary; the price is thirty per cent below what any other customer pays. Nothing about the transaction being routine makes the terms fair — and routine transactions are the easiest place to hide value transfer, because nobody looks twice at an invoice that resembles a thousand others.

At arm's length, but not in the ordinary course. A manufacturing company sells its head office building to a director at an independently valued price. The price is defensible. But the company has disposed of a major asset in a transaction outside anything it normally does, and the shareholders have a legitimate interest in whether that should happen at all — a question the price does not answer.

So both limbs are required, and each closes what the other leaves open. In practice the harder one to establish is arm's length, because it requires evidence: comparable third-party pricing, the same terms offered to unrelated parties, a documented basis.

The wholly owned subsidiary exemption rests on entirely different reasoning. There is no minority — the holding company owns every share, so there is nobody on the subsidiary's side who could be prejudiced. And the condition that the accounts are consolidated and laid before shareholders at AGM means the holding company's own members see the combined position, with intra-group transactions eliminated on consolidation.

What the exemption does not do is remove the section 177 requirement of audit committee approval, which applies to related party transactions generally.

Which approval applies

TransactionBoard approvalOrdinary resolution
Ordinary course and arm's lengthNot required under section 188Not required
Not in ordinary course, or not at arm's lengthRequiredIf above the prescribed threshold
Holding to wholly owned subsidiary, accounts consolidatedPer the sectionNot required
Any related party transactionAudit committee approval under section 177 remains

Evidencing arm's length

  1. Comparable pricing to unrelated customers or suppliers for the same goods or services.
  2. The same credit terms, discounts and delivery obligations as third parties receive.
  3. A written basis of pricing approved before the transaction, not reconstructed afterwards.
  4. A record that the terms were tested, not merely asserted.
  5. Periodic review, since terms that were arm's length once may cease to be.

Common mistakes

  • Treating the ordinary course exemption as satisfied by the ordinary course limb alone.
  • Asserting arm's length pricing without comparable evidence.
  • Applying the subsidiary carve-out to a subsidiary that is not wholly owned.
  • Assuming the exemption also removes audit committee approval.

Key Facts About Ordinary Course Exemption

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

Which transactions do not require shareholder approval under section 188?

Transactions in the ordinary course of business and on an arm's length basis; and transactions between a holding company and a wholly owned subsidiary whose accounts are consolidated and laid before the shareholders at the annual general meeting.

When is Board approval required?

Board approval is required for contracts or arrangements with related parties specified in section 188(1)(a) to (g) which are either not in the ordinary course of business or not at arm's length.

Over 90% of compliance penalties in India arise from missed due dates — timely handling can save businesses thousands of rupees each year.

— TaxClue Compliance Desk

Ordinary Course Exemption: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Frequently Asked Questions
Which transactions do not require shareholder approval under section 188?
Transactions in the ordinary course of business and on an arm's length basis; and transactions between a holding company and a wholly owned subsidiary whose accounts are consolidated and laid before the shareholders at the annual general meeting.
When is Board approval required?
Board approval is required for contracts or arrangements with related parties specified in section 188(1)(a) to (g) which are either not in the ordinary course of business or not at arm's length.
When is shareholder approval required?
Where the transactions exceed the prescribed threshold, prior approval by ordinary resolution of the company is required.
Must both conditions be met for the first exemption?
Yes. The transaction must be both in the ordinary course of business and on an arm's length basis.
Why is a wholly owned subsidiary treated separately?
Because there is no minority to protect and the accounts are consolidated, so the transaction is visible to the shareholders who see the consolidated statements.
Does the exemption remove the need for audit committee approval?
No. Approval of the audit committee under section 177 is a separate requirement.
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Vikas Sharma VERIFIED EXPERT
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Experienced in company registration, GST, trademark, and compliance. Helping Indian businesses stay compliant.
Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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