Thursday, February 27, 2014

MCA clarification on section 185 of the Companies Act 2013




Ministry of Corporate Affairs (MCA) had notified 98 sections of Companies Act 2013 in September 2013. These 98 sections included Section 185 of the Act also. The Section 372A of Companies Act 1956 is still to be repealed and Section 186 of Companies Act 2013 is pending to be notified.

Under Companies Act 1956, the section 372A deals with the Inter-Corporate Loans and Investments by Public companies. The section 186 under Companies Act 2013, regulates Inter-Corporate Loans and Investments and since this section of the new act is pending to be notified, its corresponding provision, Section 372A of the 1956 Act, continues to be in force.

Section 185 of Companies Act 2013 (replaces the old section 295 of the Companies Act, 1956) provides for loans to directors, and is applicable to private and public companies, while the old section 295 was not applicable to private companies, unless such private company was the subsidiary of a public company.

Section 372A of the Companies Act, 1956, specifically exempts any loans made, guarantee given or security provided or any investment made by a holding company to its wholly owned subsidiary.

As against section 372A, the new section 185 of Companies Act 2013, prohibits guarantee given or security provided by a holding company in respect of loans taken by its subsidiary company except in ordinary course of business.

The above situation of contradiction between provisions of Sec 185 and Sec 372A lead to the confusion. In light of this, MCA has vide its circular dated February 14, 2014 issued a clarification regarding the applicability of Sec 372A till it is repealed and notified. MCA has clarified that any guarantee given or security provided by a holding company in respect of loans made by a bank or financial institution to its wholly owned subsidiary company, exemption as provided in clause (d) of sub-section (8) of Section 372A of the Companies Act, 1956 shall be applicable. MCA has specifically added that this clarification will, however, be applicable to cases where loans so obtained are exclusively utilized by the subsidiary for its principal business activities.

The MCA circular on clarification is available at :

No comments:

Post a Comment

Note: Only a member of this blog may post a comment.