Companies Act · Share Allotment

PAS-3 Return of Allotment: Share Issue and Private Placement Controls

Finin2min Compliance Desk·June 2026·7 min readPAS-3

Share allotment creates a legal record, not just an investor cap-table update. PAS-3, registers, board approvals and private-placement controls must tell the same story.

Section 39 and PAS-3 link

Section 39 includes that whenever a company having a share capital makes an allotment of securities, it shall file with the Registrar a return of allotment in such manner as may be prescribed.

Private placement control

Section 42 covers issue of shares on private placement basis and should be reviewed where securities are offered to identified persons rather than through public offer mechanics.

Allotment file checklist

DocumentPurpose
Board/shareholder approvalSupports authority for issue/allotment.
Offer/application recordsSupports terms and identified allottees.
Bank receipt of considerationSupports money trail.
List of allotteesBasis for PAS-3 and register update.
Updated register of members/security holdersPermanent statutory record.

Finin2min warning

Do not update the cap table before legal closure. PAS-3, registers and money trail must match exactly.
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Official sources used

This article is intentionally source-limited to official MCA / India Code material. Verify final filing positions with the latest Act, Rules, MCA forms and portal advisories before publishing.

FAQs

What is PAS-3 broadly used for?

It is the return-of-allotment filing route where a company with share capital makes an allotment of securities.

Which sections are key for allotment?

Section 39 covers allotment return, and Section 42 matters for private placement.

Should registers be updated after allotment?

Yes. Statutory registers should match allotment filings and cap table.