February 2, 2016
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Filing delay framework: clarify limited immunity for certain statutory filings and increase additional fees to deter non compliance.
The Committee recommended clarifying that the 270 day additional fee immunity from prosecution applies only to six specified statutory filings (declaration of beneficial interest, annual returns, resolutions and agreements, listed-company AGM reports, financial statements, and director identification intimation), substantially increasing additional fees to deter non compliance, reducing the ordinary filing fee to zero for filings made within the original prescribed period, and specifying in the Rules that condonation under Section 460 is a separate process and not a prerequisite to filing belated documents.