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Microlesson · 5-min read

Prohibition for Buy-back in Certain Circumstances

# Prohibition for Buy-back of Shares (Section 70)

## Overview

Section 70 of the Companies Act, 2013 lays down circumstances where a company is prohibited from buying back its own shares or other specified securities, either directly or indirectly.

## Absolute Prohibitions (Section 70(1))

No company shall directly or indirectly purchase its own shares or specified securities in the following situations:

### A. Through Restricted Channels

1. Through any subsidiary company (including its own subsidiary companies); or

2. Through any investment company or group of investment companies

### B. Where Default Exists

If the company has defaulted in any of the following:

#Nature of Default
iRepayment of deposits or interest thereon
iiRedemption of debentures
iiiRedemption of preference shares
ivPayment of dividend to any shareholder
vRepayment of any term loan or interest thereon to financial institutions or banking company

Important Relief: Where the default has been remedied and a period of 3 years has lapsed after such default ceased to subsist, the buy-back is not prohibited.

## Prohibitions Linked to Non-Compliance (Section 70(2))

A company is further prohibited from buy-back if it has not complied with the provisions of:

SectionSubject Matter
Section 92Annual Return
Section 123Declaration and Payment of Dividend
Section 127Punishment for failure to distribute dividends
Section 129Financial Statement

## Key Definition

Specified Securities [Explanation I to Section 68] includes:

  • Employees' Stock Option (ESOP)
  • Other securities as may be notified by the Central Government from time to time

## Quick Recall Chart

```

Buy-back PROHIBITED if:

Route problem → via subsidiary OR investment company

Default problem → deposits, debentures, pref shares, dividend, term loan

(unless remedied + 3 years passed)

Compliance gap → Sec 92 / 123 / 127 / 129 not complied

```

Worked example

### Example 1

Example 1: XYZ Ltd. defaulted in repayment of a term loan to SBI on 1st April 2022. The default was rectified on 1st June 2022. Can XYZ Ltd. undertake buy-back in July 2024?

Answer: No. Although the default has been remedied, the 3-year cooling-off period from the date the default ceased to subsist (i.e., 1st June 2022) ends on 1st June 2025. Therefore, buy-back is still prohibited in July 2024.

### Example 2

Example 2: ABC Ltd. wishes to buy-back its shares through its wholly-owned subsidiary PQR Ltd. Is this permissible?

Answer: No. Section 70(1)(a) expressly prohibits buy-back through any subsidiary company, including own subsidiary companies. The buy-back is invalid.

⚠️ Common exam mistakes

  • Confusing the 3-year cooling period — it starts from the date the default ceased to subsist, NOT from the date of original default.
  • Forgetting that prohibitions under Section 70(2) [non-compliance of Sec 92, 123, 127, 129] are SEPARATE from the default-based prohibitions in Section 70(1).
  • Treating the prohibition on buy-back through subsidiary as applicable only to non-wholly owned subsidiaries — it applies to ALL subsidiaries including wholly-owned ones.
  • Missing that 'specified securities' includes ESOP and other CG-notified securities, not just equity shares.
Bare-Act text Section 70 · Companies Act, 2013 · click to expand
Section 70 – Prohibition for Buy-back in certain circumstances: (1) No company shall directly or indirectly purchase its own shares or other specified securities— (a) through any subsidiary company including its own subsidiary companies; (b) through any investment company or group of investment companies; or (c) if a default, is made by the company, in the repayment of deposits accepted either before or after the commencement of this Act, interest payment thereon, redemption of debentures or preference shares or payment of dividend to any shareholder, or repayment of any term loan or interest payable thereon to any financial institution or banking company: Provided that the buy-back is not prohibited, if the default is remedied and a period of three years has lapsed after such default ceased to subsist. (2) No company shall, directly or indirectly, purchase its own shares or other specified securities in case such company has not complied with the provisions of sections 92, 123, 127 and section 129.
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