Form PAS-3 return of allotment: the 15-day and 30-day rules and what to attach

Last updated 23 Oct 2026 · India

Short answer. When a company allots shares it files a return of allotment in Form PAS-3. For a private placement, section 42(8) of the Companies Act 2013 requires it within 15 days of allotment. For other allotments, such as a rights issue or bonus, section 39(4) with Rule 12 of the Companies (Prospectus and Allotment of Securities) Rules 2014 gives 30 days. Under section 42 the money must be received by cheque, demand draft or banking channels, never cash, and allotment must be made within 60 days of receiving the application money, or the money must be refunded.

Which clock applies

Type of allotment	PAS-3 due	Main provision
Private placement (PAS-4 offer)	15 days from allotment	s.42(8)
Rights issue, bonus, ESOP, conversion	30 days from allotment	s.39(4), Rule 12

Attach with PAS-3

Certified copy of the board or shareholders' resolution for the allotment
List of allottees (name, address, number and class of shares, amount paid)
For a private placement: the special resolution and the PAS-5 record of offer
Valuation report where shares are issued for consideration other than cash

Common mistakes

Using the money before allotment. Under s.42 the application money stays in a separate bank account until allotment.
Allotting after 60 days. Money not allotted within 60 days must be repaid within 15 days, with interest after that.
Cash receipts. Private placement money must come through banking channels.
Wrong authorised capital. If the allotment takes paid-up capital above authorised capital, increase it first (SH-7) or PAS-3 will be marked for resubmission.

Checklist

Authorised capital enough
Separate bank account (private placement)
Allotment within 60 days of receipt
PAS-3 within 15 or 30 days with list of allottees

Frequently asked questions

What is the due date of PAS-3 for private placement?

15 days from the date of allotment (section 42(8) of the Companies Act 2013).

What is the due date of PAS-3 for a rights issue?

30 days from allotment, under section 39(4) and Rule 12 of the Prospectus and Allotment Rules.

Can private placement money be received in cash?

No. Section 42 requires payment by cheque, demand draft or other banking channels.

Official sources

Not tax or legal advice. This is a free explainer of public rules; deadlines and rules can change by notification, so confirm on the official portal or with your CA before you file. Last checked 23 Oct 2026.

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