TaxTMI 
TaxTMI 
TaxTMI 
A Pvt. Ltd company which was a small company until 31st March,2025, became a non small company in May 2025 by increasing its paid up capital. It has not yet obtained ISIN because of 18 months window available as per Rule 9B of Prospectus and allotment rules. So is such a company required to file PAS 6 for the half year ending Sep, 2025? As PAS 6 cannot be filed without ISIN, would this constitute as non-compliance?
ISIN requirement and PAS 6 filing
Nishtha Jain
PAS-6 filing duty after losing small company status during Rule 9B demat window without ISIN clarified A private company that ceased to qualify as a small company in May 2025 by increasing its paid-up capital is assessing its obligation to file Form PAS-6 for the half-year ending September 2025. Under Rule 9B of the Companies (Prospectus and Allotment of Securities) Rules, there is an 18-month window to obtain ISIN and dematerialise securities. The issue is whether PAS-6 is still mandatorily required during this window, given that the form cannot be filed without an ISIN, and if failure to file would amount to non-compliance. (AI Summary)