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Microlesson · 5-min read

Sections 390–393 – Indian Depository Receipts, Misstatement Liability, Closure of Business, Penalty

## Sections 390–393 – Other Provisions for Foreign Companies

### Section 390 – Indian Depository Receipts (IDR)

The Central Government may make rules governing the issue of IDRs by companies incorporated outside India. The rules deal with:

(i) the offer of IDRs;

(ii) disclosures required in the prospectus for the issue of IDRs;

(iii) the manner in which the depository deals with IDRs; and

(iv) the transfer and transmission of IDRs.

### Section 391 – Application of Sections 34, 35 & 36 to Foreign Companies

Sections 34–36 of the Companies Act apply mutatis mutandis to a foreign company that issues a prospectus or raises securities in India:

  • Sec. 34 – Criminal liability for misstatement in prospectus.
  • Sec. 35Civil liability for misstatement.
  • Sec. 36 – Fraudulently inducing a person to invest.

Closure of Indian place of business: If a foreign company has raised money from Indians by issuing securities, and the amount has not yet been repaid or redeemed, then to close its place of business in India it must comply with Section 376 AND Chapter XX (winding-up). It cannot simply walk away.

### Section 392 – Punishment for contravention

DefaulterPenalty
Foreign CompanyFine Min ₹1,00,000 – Max ₹3,00,000 AND ₹50,000 per day for continuing default
Every Officer in defaultFine Min ₹25,000 – Max ₹5,00,000

### Section 393 – Effect of failure to comply

If a foreign company fails to comply with the provisions of the Act:

  • It cannot sue anyone in India, and
  • It is not eligible for set-off in any legal proceedings.

BUT — it can be sued by Indian creditors and stakeholders.

This is the 'sword without a shield' consequence — a powerful incentive for foreign companies to comply.

Worked example

### Example 1

Q. A foreign company that has failed to file FC-3 and FC-4 for two years now wants to recover ₹50 lakh from an Indian customer. Can it sue?

A. No. Under Section 393, a non-compliant foreign company cannot institute a suit or claim a set-off in India, though the customer (or anyone else) can still sue it.

### Example 2

Q. Compute the maximum fine on a foreign company that has continued in default for 90 days.

A. Fine: maximum ₹3,00,000 PLUS ₹50,000 × 90 days = ₹45,00,000. Total upper limit = ₹48,00,000.

⚠️ Common exam mistakes

  • Believing that closure of an Indian place of business is automatic on cessation of activities — repayment/redemption obligations to Indian investors must be discharged first (Sec. 376 + Chapter XX).
  • Forgetting that Section 393 is one-sided: non-compliant foreign companies can still be sued, only their right to sue is suspended.
  • Confusing the ₹50,000 per day with a daily officer-level penalty — it applies only to the company.
Bare-Act text Sections 390, 391, 392 & 393 · Companies Act, 2013 · click to expand
Section 393 — No foreign company shall be entitled to bring any suit, claim any set-off, make any counter-claim or institute any legal proceedings in respect of any contract, until it has complied with the provisions of this Act applicable to it.
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