PAS-3 Late Filing Penalty Calculator
Estimate the MCA additional fee plus the Section 39(5)/450 penalty for filing your Return of Allotment late — company and officers in default, all on one screen.
- Free — no sign-up
- Instant, on-screen results
- Built by our CA · CS team
- Rules cited on the page
Enter your figures — the result on the right updates as you type.
Penalty breakdown
File your PAS-3 & fix late-filing exposure with a CS
We prepare the Return of Allotment, compute exact fees and, where possible, help with adjudication/condonation.
Disclaimer: Indicative estimate only. Additional fees and adjudication penalties are finally determined by MCA/RoC and may vary with facts, share-capital slab and adjudication orders. Verify on the MCA portal or with a professional before filing.
What is Form PAS-3 (Return of Allotment)
Form PAS-3 is the Return of Allotment a company files with the Registrar of Companies whenever it allots shares — on incorporation subscription, rights issue, bonus, private placement or preferential allotment. Under Section 39(4) of the Companies Act, 2013 read with the Companies (Prospectus and Allotment of Securities) Rules, PAS-3 must be filed within 30 days of the allotment (15 days in the case of a private placement under Section 42). Miss the window and two charges stack up: an MCA additional fee (a multiple of the normal fee) and a Section 39(5)/450 penalty.
Additional-fee slab multiplier
The MCA additional fee for late PAS-3 is charged as a multiple of the normal filing fee, and the multiplier grows with the length of the delay. The Section 39(5) penalty runs in parallel and is not affected by this slab.
| Up to 15 days | 1× |
| More than 15 & up to 30 days | 2× |
| More than 30 & up to 60 days | 4× |
| More than 60 & up to 90 days | 6× |
| More than 90 & up to 180 days | 10× |
| More than 180 days | 12× |
| Rate of penalty | ₹1,000 / day |
| Cap per person | ₹1,00,000 |
| On the company | Yes |
| On each officer in default | Yes |
Worked example
A company allots shares and files PAS-3 40 days after the deadline. The normal filing fee is ₹300 and there are 2 officers in default besides the company.
Key terms explained
Section 39 — allotment of securities
Section 39(4) requires filing the Return of Allotment (PAS-3) with the Registrar. Section 39(5) prescribes the penalty for default — ₹1,000 per day of continuing default, capped at ₹1,00,000, on the company and every officer in default.
30-day / 15-day deadline
PAS-3 must be filed within 30 days of allotment. For a private placement under Section 42 the return is due within 15 days. The "days delayed" input is counted from that deadline, not from the allotment date.
Additional fee
A separate MCA charge for late filing, levied as a multiple of the normal fee (1× to 12×) depending on how long the filing is delayed. It is over and above the Section 39(5) penalty.
Officer in default
Directors, KMP and other officers who are responsible for the compliance. Each officer in default bears the ₹1,000/day penalty separately, up to ₹1,00,000 each, in addition to the company's own penalty.
Questions people ask
Short answers on PAS-3 Late Filing Penalty. Tap a question to open it.
01What is Form PAS-3?
The return of allotment filed with the Registrar whenever a company allots shares — on a rights issue, a private placement, a preferential allotment, conversion of a loan, or an ESOP exercise. It carries the list of allottees and the valuation report where required.
02When is PAS-3 due?
Within 30 days of the allotment. For a private placement the allotment itself must be made within 60 days of receiving the money, and the company cannot use the money until PAS-3 is filed.
03What is the penalty for filing PAS-3 late?
The additional fee applies on the usual delay multiples. For a private placement, section 39(5) provides a penalty of ₹1,000 for each day of default on the company and each officer, subject to a maximum of ₹1,00,000.
04Why does the money have to stay in a separate account?
For a private placement, section 42 requires the application money to be kept in a separate bank account and not utilised until the allotment is made and PAS-3 filed. Using it earlier is a substantive contravention, not a procedural one.
05Is a valuation report always needed?
For a preferential allotment or private placement, yes — a registered valuer's report supports the issue price. A rights issue to existing shareholders in proportion does not require one, though the price should still be defensible.
More Company & MCA tools
Picked from the same shelf. Every tool is free and runs in your browser.
Disclaimer: This tool gives indicative results for general guidance only and is not professional advice. Please verify with a qualified CA before acting on the numbers.