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Microlesson · 5-min read

Section 7 – Incorporation of Company: Procedure, Documents, CIN and Penalties

## Section 7 – Incorporation of Company

### Step 1: Documents to be filed with RoC (with SPICe+ Form INC-32)

File with the Registrar within whose jurisdiction the Registered Office (RO) is proposed to be situated:

DocumentParticulars
MoA (eMoA — INC-33) and AoA (eAoA — INC-34)Duly signed by subscribers
Declaration (INC-8)By Advocate/CA/CS/Cost Accountant in practice engaged in formation AND by a person named in AoA as director/manager/secretary — confirming compliance with the Act
Address for correspondenceUntil RO is established
Particulars of subscribersName, residential address, nationality, proof of identity
Particulars of first directorsName, DIN, residential address, nationality, proof of identity + interest in other firms/body corporates + consent in DIR-2 + filing in DIR-12
Declaration in INC-9 (from each subscriber and first director)(a) Not convicted of offence re: promotion/formation/management of any company; (b) Not found guilty of fraud/misfeasance/breach of duty in last 5 years; (c) All documents filed with RoC contain correct, complete and true information

### Additional points

  • All documents are filed along with SPICe+ (INC-32)Simplified Proforma for Incorporating a Company Electronically — mandatory for ALL companies.
  • For an OPC, written consent of the nominee must also be attached.
  • If the company's objects need prior approval from a sectoral regulator (e.g., RBI, SEBI), such approval must be obtained and attached.
  • For a Nidhi Company, declaration under Section 406 from the Central Government must be obtained.

### Step 2: Signing of MoA/AoA (Rule 13)

Subscriber typeManner of signature/authentication
IndividualAdd name, address, description, occupation; sign in presence of at least 1 witness who also attests with same details
IlliterateThumb impression/mark affixed; a writer to write his name near the mark, authenticate with signature, state shares taken
Body CorporateSigned by director/officer/employee authorised by Board Resolution; the authorised person cannot himself be a subscriber
LLPSigned by a partner authorised by resolution of all partners; authorised person cannot himself be a subscriber
Foreign national (residing abroad)Signature, address and ID proof must be notarized by Notary Public
Foreign national (visiting India)Allowed if holding a valid Business Visa. Business Visa is N.A. to PIO/OCI

### Step 3: Certificate of Incorporation (CoI)

RoC issues CoI in Form INC-11 based on documents submitted.

### Step 4: Allotment of Corporate Identity Number (CIN)

RoC allots a unique CIN, included in the CoI.

#### Decoding CIN — example: Infosys Ltd → L85110KA1981PLC013115

SegmentMeaningExample
LStatus (L=Listed; U=Unlisted)L
85110Industry code85110
KAState of incorporationKA (Karnataka)
1981Year of incorporation1981
PLCCompany type (PLC/Pvt/NPL)PLC
013115Registration number with RoC013115

### Step 5: Preservation of documents

Company must maintain at its RO copies of all documents originally filed under Section 7(1) till dissolution.

### Penalty for furnishing false information

  • Any person who furnishes false/incorrect particulars or suppresses material information → liable under Section 447 (fraud).

### Consequences of post-incorporation discovery of fraud

If, after incorporation, it is proved the company was incorporated by furnishing false info or by fraudulent action:

  • (a) Promoters, first directors and persons making declaration liable under Section 447
  • (b) Tribunal (NCLT), on application, may pass [Mnemonic: MR. LOW]:
  • M — Regulate Management of the company (changes in MoA/AoA)
  • L — Direct Liability of members to be unlimited
  • RRemove name of company from register
  • WWinding up of the company
  • O — Pass such Other orders as it deems fit

Before making such orders, the company must be given a reasonable Opportunity Of Being Heard (OOBH) and NCLT shall take into account transactions entered into by the company.

Worked example

### Example 1

Example (CIN decoding): A CIN reads U72200MH2019PTC123456. Decoding: U = Unlisted; 72200 = Industry code (software services); MH = Maharashtra; 2019 = Year of incorporation; PTC = Private Limited Company; 123456 = RoC Registration No.

### Example 2

Example (Fraudulent incorporation): XYZ Pvt. Ltd. was incorporated by suppressing the fact that one director was convicted of fraud. NCLT, on application, may: order changes in MoA/AoA, declare members' liability unlimited, remove the company's name from register, order winding up, or pass any other order — after giving OOBH to the company.

### Example 3

Example (Foreign subscriber): A subscriber is a US national residing in New York. The MoA/AoA must be signed and notarized by a Notary Public in the USA before filing in India.

⚠️ Common exam mistakes

  • Forgetting that SPICe+ (INC-32) is the mandatory single form for incorporating all companies.
  • Confusing INC-8 (declaration of compliance) with INC-9 (declaration by subscribers/first directors of no conviction etc.) and INC-11 (Certificate of Incorporation).
  • Believing that an OCI/PIO with a Business Visa can sign MoA — Business Visa route is not available to OCI/PIO.
  • Forgetting that a Body Corporate or LLP subscriber must have an authorised signatory who is not himself a subscriber.
  • Missing that for a Nidhi Company, CG declaration u/s 406 must be obtained at the incorporation stage itself.
Bare-Act text Section 7 · Companies Act, 2013 · click to expand
Section 7(1): There shall be filed with the Registrar within whose jurisdiction the registered office of a company is proposed to be situated, the following documents and information for registration, namely — (a) the memorandum and articles of the company duly signed by all the subscribers... (b) a declaration in the prescribed form by an advocate, a chartered accountant, cost accountant or company secretary in practice... (c) a declaration from each of the subscribers... (d) the address for correspondence till its registered office is established; (e) the particulars of name, address... of every subscriber; (f) the particulars of the persons mentioned in the articles as the first directors...; (g) the particulars of the interests of the persons mentioned in the articles as the first directors of the company in other firms or bodies corporate along with their consent to act as directors.
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