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PAS-3 Return of Allotment Filing Services

Reviewed by CA and CS Team, Patron Accounting LLP ICAI & ICSI Registered| 15+ Years Experience| Last Updated: Verify Credentials →

Documents: List of allottees, certified board resolution, valuation and offer records.

Fees: PAS-3 filing starting from INR 4,999 (Exl GST and Govt. Charges).

Timeline: Within 30 days of allotment, or 15 days for private placement.

Covers: Fresh issues, rights, bonus, preferential allotment and ESOP exercise.

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PAS-3 Filing: Overview and Quick Summary

📌 TL;DR - PAS-3 Filing Services at a Glance

Form PAS-3 is the return of allotment a company files with the Registrar of Companies after issuing shares, under Section 39(4) of the Companies Act, 2013. It is due within 30 days of allotment, or within 15 days for a private placement under Section 42(9). It applies to fresh issues, rights, bonus, preferential allotment and ESOP exercise.

Parameter	Detail
Governing Provision	Section 39(4) and 42(9), Companies Act, 2013; Rule 12 and Rule 14
Applicable To	Any company allotting shares or securities
Timeline	30 days from allotment; 15 days for private placement
Cost	Patron fee from INR 4,999 (Exl GST and Govt. Charges) plus MCA fee
Penalty	Rs 1,000/day (max Rs 1,00,000 general; up to Rs 25,00,000 private placement)
Form / Portal	Form PAS-3 on the MCA V3 portal; up to 5 allotments per form
Authority	Registrar of Companies (ROC), Ministry of Corporate Affairs

PAS-3 filing services from Patron Accounting cover the list of allottees, certified board resolution and ROC submission on the MCA V3 portal. We file PAS-3 alongside the underlying share issue so your capital structure is recorded correctly and on time. Our team has supported 10,000+ businesses since 2009.

PAS-3 follows the underlying issue of shares, and where the issue needs headroom we also handle the related change in authorised capital so the allotment is recorded cleanly.

What Is Form PAS-3?

Form PAS-3 is the return of allotment a company files with the Registrar of Companies to report that it has issued shares or securities, under Section 39(4) of the Companies Act, 2013. It records the allottees and the change in the company’s paid-up capital.

It must be filed within 30 days of allotment for a general issue, and within 15 days for a private placement under Section 42(9). The form covers fresh issues, rights, bonus, preferential allotment and ESOP exercise, with a list of allottees attached.

Key Terms for PAS-3 Filing:

Return of Allotment: The statement to the ROC that shares have been issued, filed in PAS-3.
Allottee: A person to whom the company allots shares; their details form the mandatory list of allottees.
Private Placement: An offer of securities to a select group under Section 42, filed in PAS-3 within 15 days.
Rights Issue: An offer of new shares to existing shareholders in proportion to their holding.
Bonus Issue: An allotment of free shares to existing shareholders from reserves.

Section 39/42 Form PAS-3

When Is PAS-3 Required?

Any company that allots shares or securities must file PAS-3. The deadline depends on the route of allotment, but the obligation applies to every type of issue.

Fresh issue and preferential allotment: File within 30 days of allotment under Section 39(4) and Rule 12.
Private placement: File within 15 days of allotment under Section 42(9) and Rule 14.
Rights issue and bonus issue: File within 30 days of allotment.
ESOP exercise: File PAS-3 when shares are allotted on exercise of options.
Allotment timeline: Shares must be allotted within 60 days of receiving application money, failing which the money is refunded within 15 days, with 12 percent interest thereafter.

Issuing shares? See our issue of shares service and we file the related PAS-3.

Our PAS-3 Filing Services

Service	What We Do
List of Allottees Preparation	We prepare the certified list of allottees with names, addresses, occupations and the number of securities allotted to each.
Board Resolution and Records	We compile the certified board resolution for the allotment and the supporting records, including the offer letter where required.
Private Placement Compliance	For private placements, we manage the MGT-14 before the letter of offer, the PAS-5 record and the 15-day PAS-3 filing.
Capital Structure Update	We reconcile the pre and post allotment capital structure so the ROC record reflects the correct paid-up capital.
MCA V3 Filing with DSC	We file PAS-3 on the MCA V3 portal using a director’s or company secretary’s DSC and share the SRN.
Share Certificate and Register Support	We help issue share certificates within 2 months and update the register of members after allotment.

Our Process

PAS-3 Filing Process: Step by Step

How Patron files Form PAS-3, from receiving application money and passing the allotment resolution to filing within the deadline and issuing share certificates.

Step 1

Receive Application Money

Collect the share application money in the company account and complete pre-allotment compliances.

In company account Pre-allotment

Money 01

Step 2

Pass the Allotment Resolution

Hold the Board meeting and pass the allotment resolution within 60 days of receiving the money.

Board meeting Within 60 days

Resolve 02

Step 3

Prepare the List of Allottees

Compile the certified list of allottees and the capital structure before and after allotment.

Certified list Capital structure

List 03

Step 4

Complete Form PAS-3

Enter allotment details on the MCA V3 portal, filing up to 5 allotments per form.

MCA V3 5 per form

Form 04

Step 5

Attach Documents and Certify

Attach the board resolution and list of allottees, certified by the signatory.

Board resolution Certified

Attach 05

Step 6

File Within the Deadline

Submit within 30 days, or 15 days for a private placement, and pay the MCA fee.

30 or 15 days Pay fee

File 06

Step 7

Issue Certificates and Update Records

Issue share certificates within 2 months and update the register of members.

Within 2 months Register updated

Certify 07

Documents Required for PAS-3 Filing

Company CIN and registered office details.
Certified board resolution approving the allotment.
List of allottees with full particulars.
Capital structure before and after allotment.
Offer letter, PAS-5 and MGT-14 SRN for private placement.
Valid DSC of the signing director or company secretary.

Need the full checklist? We share a ready PAS-3 document checklist when you book a filing slot.

Common PAS-3 Filing Challenges and Solutions

Challenge	Impact	How Patron Accounting Solves It
Confusing the 15-day and 30-day deadlines	Private placement is 15 days; general allotment is 30 days. We identify the route at the start and file within the correct window.
Using private placement money before filing	Private placement money cannot be utilised until PAS-3 is filed. We file promptly so funds are usable without breach.
Incomplete list of allottees	An incorrect or uncertified list of allottees causes rejection and penalty risk. We prepare and certify it carefully.
Missing the MGT-14 step	Private placement needs MGT-14 before the letter of offer. We sequence the filings so nothing is missed.

PAS-3 Filing Fees

Fee Component	Amount
Patron Accounting Professional Fees	Starting from INR 4,999 (Exl GST and Govt. Charges)
What it covers	List of allottees, board resolution support and PAS-3 filing
MCA statutory filing fee	Charged on actual basis; depends on nominal share capital
Late filing	Rs 1,000 per day; up to Rs 1,00,000 general, up to Rs 25,00,000 private placement

All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

The MCA statutory filing fee is charged on an actual basis and depends on the company’s nominal share capital. Late filing attracts Rs 1,000 per day, up to Rs 1,00,000 for a general allotment and up to Rs 25,00,000 for a private placement. Contact us for a detailed quote.

Get a free PAS-3 Filing consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

How Long Does PAS-3 Filing Take?

Stage	Estimated Timeline
Patron filing turnaround	Within 2 to 3 working days of receiving the allotment resolution and list of allottees
General allotment deadline	30 days from allotment (Section 39(4))
Private placement deadline	15 days from allotment (Section 42(9))
Priority approach	Private placements prioritised because the funds cannot be used until PAS-3 is filed

Patron typically files PAS-3 within 2 to 3 working days of receiving the allotment resolution and list of allottees. The statutory deadline is 30 days from allotment, or 15 days for a private placement. Because private placement money cannot be used until filing, we prioritise those allotments to keep your funds usable.

Key Benefits

Why Choose Professional PAS-3 Filing

Correct 15 or 30-Day Deadline

The right deadline is applied by allotment route - 15 days for a private placement under Section 42(9), 30 days for a general allotment under Section 39(4).

Accurate Certified List of Allottees

The list of allottees and the pre and post allotment capital structure are prepared and certified so the form is not rejected.

Private Placement Sequencing

The MGT-14 before the letter of offer, the PAS-5 record and the 15-day PAS-3 filing are sequenced correctly so funds stay usable.

Rs 1,000/Day Penalties Avoided

On-time filing avoids the Rs 1,000 per day penalty, capped at Rs 1,00,000 for a general allotment and up to Rs 25,00,000 for a private placement.

Certificates and Register Updated

Share certificates are issued within two months and the register of members is updated after allotment.

Handled by Qualified CAs and CSs

The return of allotment is prepared and filed by qualified Chartered Accountants and Company Secretaries.

Trusted by Businesses Across India

10,000+ Businesses Served | 4.9 Google Rating | 50,000+ Documents Filed | 15+ Years

"Patron filed our PAS-3 for a private placement within the 15-day window so we could use the funds immediately." - Founder, technology startup, Bengaluru.

"They handled our rights issue allotment and PAS-3 end to end, including the list of allottees. No ROC queries." - Director, manufacturing company, Pune.

Trusted by leading brands including Hyundai, Asian Paints and Bridgestone for accounting and compliance support.

With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting serves businesses across India - both in-person and remotely.

General Allotment vs Private Placement in PAS-3

Factor	General Allotment	Private Placement
Provision	Section 39(4), Rule 12	Section 42(9), Rule 14
PAS-3 deadline	30 days from allotment	15 days from allotment
Use of money	As applicable	Only after PAS-3 is filed
Max penalty	Rs 1,00,000	Rs 25,00,000

Related Share and Capital Services

PAS-3 follows a share issue. Patron handles the underlying allotment and the PAS-3 together.

Issue of Shares for fresh issues, rights and preferential allotment.
Change in Authorised Capital where the issue needs more authorised capital.
ESOP Management and Compliance Services for allotment on ESOP exercise.
Transfer of Shares for share transfers after allotment.
Private Limited Company Compliance for ongoing ROC management.

Legal and Compliance Framework

General allotment: Section 39(4) of the Companies Act, 2013, read with Rule 12 of the Companies (Prospectus and Allotment of Securities) Rules, 2014, requires PAS-3 within 30 days of allotment.

Private placement: Section 42(9), read with Rule 14, requires PAS-3 within 15 days, and the money raised cannot be used until the return is filed.

Penalty: Under Section 39(5), default in a general allotment attracts Rs 1,000 per day or Rs 1,00,000, whichever is less. Under Section 42, a private placement default attracts Rs 1,000 per day up to Rs 25,00,000 on the company, promoters and directors.

Allotment timeline: Securities must be allotted within 60 days of receiving application money, failing which it is refunded within 15 days, with 12 percent interest thereafter.

Refer to the MCA portal for filing and to Section 39 on IndiaCode for the bare provision.

What is the due date for filing Form PAS-3?

Form PAS-3 must be filed within 30 days of allotment for a general issue under Section 39(4), and within 15 days of allotment for a private placement under Section 42(9). The deadline depends on the route of allotment. A separate return is filed for each allotment, with up to five allotments allowed per form.

When is PAS-3 required?

PAS-3 is required whenever a company allots shares or securities, including a fresh issue, rights issue, bonus issue, preferential allotment, private placement and allotment on ESOP exercise. The return reports the list of allottees and the change in paid-up capital to the Registrar, keeping the company’s capital structure on public record.

What is the penalty for late filing of PAS-3?

For a general allotment under Section 39(5), the company and every officer in default are liable to Rs 1,000 per day or Rs 1,00,000, whichever is less. For a private placement under Section 42, the company, promoters and directors are liable to Rs 1,000 per day of continuing default, up to a maximum of Rs 25,00,000.

Can private placement money be used before filing PAS-3?

No. Money raised through a private placement cannot be utilised until the company files the return of allotment in Form PAS-3 with the Registrar. The funds must be kept in a separate scheduled bank account and used only for allotment or refund. Using the money before filing PAS-3 is a contravention of Section 42.

What documents are attached to PAS-3?

PAS-3 requires a certified list of allottees with their names, addresses, occupations and securities allotted, and a certified copy of the board resolution approving the allotment. A bonus issue needs the special resolution, a private placement needs the offer record and PAS-5, and an allotment for consideration other than cash needs the stamped contract.

How many allotments can one PAS-3 cover?

As per the PAS-3 instruction kit, details of up to five allotments can be filed through a single eForm. Where a company has made more than five allotments, additional PAS-3 forms are filed. Each allotment must still be reported within its applicable deadline of 30 days, or 15 days for a private placement.

When must shares be allotted after receiving money?

A company must allot securities within 60 days of receiving the application money. If it cannot, it must refund the money within 15 days from the end of the 60 days. If the company fails to refund within that period, it must repay the money with interest at 12 percent per annum from the expiry of the sixtieth day.

Is MGT-14 needed for a private placement allotment?

Yes. For a private placement, the company files MGT-14 for the special resolution before circulating the letter of offer, maintains the PAS-5 record, and then files PAS-3 within 15 days of allotment. Sequencing these filings correctly is essential, which is why a professional handles the private placement process end to end.

PAS-3 last date kya hai?

General allotment ke 30 din ke andar, aur private placement ke 15 din ke andar Form PAS-3 file karna hota hai.

Return of allotment kya hai?

Shares issue karne ke baad ROC ko di jane wali jaankari Form PAS-3 me return of allotment kehlati hai.

Quick Answers

What is PAS-3 for? Reporting allotment of shares to the ROC.

What is the deadline? 30 days, or 15 days for private placement.

How many allotments per form? Up to five.

When can private placement money be used? Only after PAS-3 is filed.

Filing Deadline Reminder

Mind the route and the clock. Private placement is 15 days, general allotment is 30 days, and private placement funds stay locked until PAS-3 is filed. Late filing runs Rs 1,000 per day, up to Rs 25 lakh for private placement. File on time to keep funds usable and stay compliant.

File your PAS-3 - Call +91 945 945 6700 or WhatsApp us. We respond within 2 hours.

File Your PAS-3 with Patron Accounting

Form PAS-3 is the return of allotment filed after a company issues shares, due within 30 days, or 15 days for a private placement, under Sections 39 and 42 of the Companies Act, 2013.

Applying the right deadline, preparing an accurate list of allottees and sequencing private placement filings all demand care. Patron Accounting, with qualified CAs and CSs and offices in Pune, Mumbai, Delhi and Gurugram, files PAS-3 accurately and on time so your share allotments stay compliant.

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PAS-3 Filing Support Across India

In-person and remote PAS-3 return of allotment filing support from our offices in Pune, Mumbai, Delhi and Gurugram.

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Content Created: 3 June 2026 | Last Updated: | Next Review: 4 September 2026 | Reviewed By: CA & CS Team, Patron Accounting LLP

This page is reviewed at least yearly and updated whenever Section 39(4), Section 42(9), Rule 12, Rule 14, the Section 39(5) and Section 42 penalty tracks, the 60-day allotment / 15-day refund timeline, or the MCA V3 PAS-3 process change. Freshness Tier 1.

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