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Application for Requesting Refund of ROC Fees Paid

By Mayashree Acharya


Updated on: Feb 16th, 2022


7 min read

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The Ministry of Corporate Affairs (MCA) has introduced the ‘Application for requesting a refund of fees paid’ form through which the companies can raise a request for refund of excess, incorrect or multiple Registrar of Companies (ROC) fees paid by them. 

Companies and Limited Liability Partnerships (LLPs) file various forms from company incorporation to annual return filing on the MCA portal. The MCA system generates a Service Request Number (SRN) while filing various forms and indicates the fee to be paid for the service. The payment can be made against the SRN through challan payment, NEFT transfer, internet banking or credit card. 

When the payment is wrongly made, the company/LLP can initiate the MCA refund process to refund the paid fees by filing the ‘Application for requesting refund of fees paid’ form (‘refund form’). However, the companies or LLP having the following status are not allowed to file the application for requesting refund of fees paid form:

  • Under process of striking off.
  • Struck off/Defunct.
  • Liquidated.
  • Dissolved.
  • Converted into LLP and Dissolved.
  • Not available for e-filing.
  • Dormant.
  • Dormant u/s 455.

Reasons for Refund of ROC Fees Paid

The company can file the refund form for initiating refund of the fees paid for the following reasons:

Multiple payments

Multiple payments include cases where the company/LLP has done multiple filings, and has made multiple payments, i.e. payments made more than once for the same form/service due to the following reasons:

  • Technical problem occurring at the payment gateway, and the MCA system has not received any response. 
  • Due to network congestion or low internet speed, there may be a session time out, and the payment is debited from the payees’ accounts. However, there is no receipt of the payment, and the user/payee makes multiple payments on the same SRN.

Incorrect payments

When the company/LLP has made payment relating to an e-form or stamp duty through an incorrect option under the pay miscellaneous fee facility, the company/LLP can claim a refund of the fee due to incorrect payment. A few instances where a refund can be requested for incorrect payments are:

  • Payment of MCA filing fee to account identified for stamp duty fee.
  • Payment of stamp duty fee to account identified for MCA filing fee.
  • Single consolidated payment for multiple SRN.
  • Payment after the expiry of the SRN due date.
  • Less payment than the amount mentioned in MCA.
  • Excess payment than the amount mentioned in MCA.
  • Payment made without any SRN.

Excess payment

Excess payment includes cases where the company/LLP pays excess fee due to incorrect data entered in the e-form or incorrect data in the MCA21 system. It also includes an additional fee paid by the company/LLP because of delays in filing due to technical problems of the MCA system.

Purpose of the Refund Form

The companies and LLPs are required to make various payments on the MCA21 portal. In a number of instances, the companies and LLPs make multiple payments, incorrect payments, or excess payments while using the MCA21 services. The MCA introduced the refund process to allow the companies and LLPs to claim a refund of such payments.

The companies and LLPs can claim a refund by filing the ‘Application for requesting a refund of fees paid’ form on the MCA21 portal. The mode of payment of the refund available is through cheque or ECS.

Non-Applicability of the Refund Form

The companies/LLPs cannot claim file the refund form for the following services or e-forms:

  • Public inspection of documents.
  • Payment for transfer deeds.
  • Request for certified copies.
  • IEPF payment.
  • Stamp duty fee (D series SRN).
  • Form DIR-3.
  • STP forms.

Particulars of Refund Form

The companies/LLPs can file the refund form only when the payment status of the transaction for which the refund is sought is ‘Paid’. There is no fee for filing the refund form. The particulars to be filled in the refund form are as follows:

  • Corporate identity number (CIN), Bank Corporate Identification Number (BCIN), Limited Liability Partnership Identification Number (LLPIN) or SRN of Application form for the availability of name.
  • Name and registered address of the office of the company, LLP or bank.
  • Name of the applicant (when the company/LLP is under liquidation or in case the LLP/company has not been incorporated or where the refund is sought does not belong to any company/LLP).
  • Mode of payment of refund, i.e. cheque or direct deposit into the bank account.
  • Payee details.
  • Bank account number.
  • In case of direct deposit into the bank account, details corresponding to the account number such as bank name, bank branch, type of account, MICR and IFSC code.
  • Reason for refund.
  • In case of incorrect payment via NEFT, details relating to the NEFT payment.
  • Information regarding the Service Request Number (SRN) of the transaction for which refund request is being made, service description, date of filing SRN, mode of payment, date of deposit of payment at the bank and the status of SRN.
  • SRN of the other transaction, if any.
  • Details of the application.
  • Verification by the person authorised by the board of directors, designated partner of the LLP or promoter.
  • DSC of the applicant, director, managing director, manager, company secretary, CFO or CFO of the company or authorised representative of LLP or authorised person of the bank.
  • DIN/DPIN, PAN or passport number of the applicant, director, managing director or designated partner, manager, CEO, CFO, company secretary or authorised person of the bank.

Documents Required for Filing a Refund Form

The below documents need to be attached along with the refund form:

  • Copy of challan duly acknowledged by bank relating to the SRN for which refund is sought.
  • Copy of challan duly acknowledged by bank relating to any other SRN, if applicable.
  • Scanned copy of the cancelled cheque.
  • Optional attachments, if any.

Time Limit For Filing Refund Form

The companies or LLPs must file the refund form within 1095 days of making payment. There will be a deduction in the amount to be refunded based on the time within which the refund form is filed. The following table shows the deduction in refund amount corresponding to the time slab for filing the refund form:

Time within which refund form is filedDefault value for deduction
0-90 days2.5%
91-180 days5%
181- 270 days7.5%
271-365 days10%
More than 365 days25%

Filing of refund form is not allowed after the expiry of 1095 days of the filing of the original request.

Disclaimer: The materials provided herein are solely for information purposes. No attorney-client relationship is created when you access or use the site or the materials. The information presented on this site does not constitute legal or professional advice and should not be relied upon for such purposes or used as a substitute for legal advice from an attorney licensed in your state.

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