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Microlesson · 5-min read

Section 8 Companies - Revocation, Winding Up, Amalgamation & Exemptions

# Section 8 Company - Post Licence Consequences & Exemptions

## 1. Revocation of Licence - Powers of Central Government

When a Section 8 company's licence is revoked, the Central Government (CG) may, in public interest, order any of the following (this is a reasonable opportunity of being heard situation):

  • Winding up under the Companies Act, 2013, OR
  • Amalgamation with another company registered under Section 8 having:
  • Similar objects
  • Similar constitution
  • Similar powers and rights (as defined by CG)

## 2. Treatment of Surplus Assets on Winding Up

After all liabilities are satisfied during winding up, if any assets remain, they may be:

OptionTreatment
Option 1Transferred to another Section 8 company having similar objects (subject to T&C imposed by Tribunal)
Option 2Sold and proceeds credited to Insolvency and Bankruptcy Fund formed u/s 224 of IBC

## 3. Restriction on Amalgamation

A Section 8 company can amalgamate ONLY with another Section 8 company having similar objectives. It cannot merge with a regular company.

## 4. Penalty for Default (Section 8(11))

DefaulterMinimum FineMaximum Fine
CompanyRs. 10 lakhsRs. 1 crore
Directors & every Officer in Default (OID)Rs. 25,000Rs. 25 lakhs

Special clause: If affairs of the company were conducted fraudulently, every OID is liable u/s 447 (fraud).

## 5. Concept Clarity Checks

1. Can a Section 8 company be incorporated with unlimited liability? — NO. A Section 8 company can only be a limited company.

2. Can an existing company seek licence u/s 8? — YES. In such case, it will drop the suffix "Ltd" or "Pvt Ltd".

3. Can a firm become a member in a normal public company? — NO. A partnership firm is not a separate legal entity.

## 6. Key Exemptions to Section 8 Companies

SectionExemption / Relaxation
2(68) & 2(71)No minimum PUSC required for private/public Section 8 companies
2(85)Definition of Small Company does NOT apply to Section 8 company
96(2)Date, time & place of AGM may be decided by Board (subject to direction given by members in GM)
101(1)Notice period for GM can be 14 clear days (instead of 21 days)
118Not fully applicable. Minutes may be recorded within 30 days if Articles provide for confirmation by circulation
136(1)Circulation of FS allowed 14 days before AGM (instead of 21 days)

Worked example

### Example 1

Example - Revocation Outcome: A Section 8 company 'Helping Hands Foundation' had its licence revoked because it diverted funds for distribution among members. CG may order winding up. On winding up, after paying all creditors, Rs. 50 lakhs remains as surplus. This Rs. 50 lakhs cannot be distributed to members. It must either be transferred to another Section 8 company with similar charitable objectives OR credited to the Insolvency and Bankruptcy Fund u/s 224 of IBC.

### Example 2

Example - Penalty Calculation: 'Edu For All', a Section 8 company, fails to comply with Section 8 requirements. The Tribunal may impose a fine between Rs. 10 lakhs and Rs. 1 crore on the company. Additionally, each director (say there are 4 directors) may face a fine between Rs. 25,000 and Rs. 25 lakhs individually.

### Example 3

Example - AGM Notice: 'Green Earth' (Section 8 company) wants to call its AGM. Due to the exemption under Section 101(1), it can issue notice with only 14 clear days notice instead of the usual 21 days, allowing faster scheduling.

⚠️ Common exam mistakes

  • Believing that a Section 8 company can amalgamate with any company - it can only merge with another Section 8 company having similar objectives.
  • Thinking surplus assets on winding up can be distributed to members - they must go to another Section 8 company or to IBC fund.
  • Assuming Section 8 companies need minimum paid-up capital - they are exempted from this requirement.
  • Forgetting that fraudulent conduct triggers Section 447 liability for officers in addition to the standard fine.
  • Confusing the small company definition applicability - it does NOT apply to Section 8 companies.
Bare-Act text Section 8 · Companies Act, 2013 · click to expand
Section 8(7)-(11) of Companies Act, 2013: Where a licence is revoked under sub-section (6), the Central Government may, by order, if it is satisfied that it is essential in the public interest, direct that the company be wound up under this Act or amalgamated with another company registered under this section.
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