New Companies Act, 2013- implications on banks

Applicability of the Companies Applicability of the Companies Act to Banks: [S 1(4)]Act to Banks: [S 1(4)]

““The provisions of The provisions of this Act shall apply tothis Act shall apply to—— …….... ((cc) ) banking companiesbanking companies, , except in so far as the said except in so far as the said

provisions are inconsistent with the provisions of the provisions are inconsistent with the provisions of the Banking Regulation Act, 1949Banking Regulation Act, 1949;;

… “… “

Scheduled Banks covered within meaning of FIsScheduled Banks covered within meaning of FIs: : [S 2(39)][S 2(39)]

““financial institutionfinancial institution” includes a scheduled bank, and any ” includes a scheduled bank, and any other financial institution defined or notified under the other financial institution defined or notified under the RBI Act, 1934;RBI Act, 1934;

05/01/23 Corporate Legal Practice

Fraudulent inducement to lend money (S Fraudulent inducement to lend money (S 36 r/w 447)36 r/w 447)

Any person who, either knowingly or Any person who, either knowingly or recklessly makes recklessly makes any statementany statement, promise or forecast which is false, , promise or forecast which is false, deceptive or misleading, or deceptive or misleading, or deliberately conceals any deliberately conceals any material factsmaterial facts , to induce another person to enter into, , to induce another person to enter into, or to offer to enter into,— (or to offer to enter into,— (aa) any agreement for, or ) any agreement for, or with a view to, acquiring, disposing of, subscribing for, with a view to, acquiring, disposing of, subscribing for, or underwriting securities; or (or underwriting securities; or (bb) any agreement, the ) any agreement, the purpose or the pretended purpose of which is to purpose or the pretended purpose of which is to secure a profit to any of the parties from the yield of secure a profit to any of the parties from the yield of securities or by reference to fluctuations in the value securities or by reference to fluctuations in the value of securities; or (of securities; or (cc) ) any agreement for, or with a view any agreement for, or with a view to obtaining credit facilities from any bank or financial to obtaining credit facilities from any bank or financial institution, institution,

shall be liable for action under section 447shall be liable for action under section 447..


Punishment for Fraud Punishment for Fraud (S 447): (S 447): Without prejudice to any liability including Without prejudice to any liability including

repayment of any debt under this Act or any other repayment of any debt under this Act or any other law for the time being in force, law for the time being in force, any person any person who is who is found to be guilty of fraud, shall be punishable with found to be guilty of fraud, shall be punishable with imprisonment for a term which shall imprisonment for a term which shall not be less not be less than six months but which may extend to ten yearsthan six months but which may extend to ten years and and shall also be liable to shall also be liable to fine fine which shall which shall not be not be less than the amount involved in the fraud, but less than the amount involved in the fraud, but which may extend to three times the amount which may extend to three times the amount involved in the fraudinvolved in the fraud: Provided that where the fraud : Provided that where the fraud in question involves in question involves public interest, the term of public interest, the term of imprisonment shall not be less than three yearsimprisonment shall not be less than three years..


Cont.. Cont..

ExplanationExplanation.—For the purposes of this section—.—For the purposes of this section— ((ii) “fraud” in relation to affairs of a ) “fraud” in relation to affairs of a company or any body company or any body

corporatecorporate, includes , includes any act, omissionany act, omission, , concealment of any concealment of any fact fact or or abuse of position abuse of position committed by any person or any committed by any person or any other person with the connivance in any manner, other person with the connivance in any manner, with with intent to deceiveintent to deceive, to gain undue advantage from, or to , to gain undue advantage from, or to injure the interests of, the company or its shareholders injure the interests of, the company or its shareholders or or its creditors its creditors or any other person, whether or not there is or any other person, whether or not there is any wrongful gain or wrongful loss;any wrongful gain or wrongful loss;

((iiii) “wrongful gain” means the gain by unlawful means of ) “wrongful gain” means the gain by unlawful means of property to which the person gaining is not legally property to which the person gaining is not legally entitled;entitled;

((iiiiii) “wrongful loss” means the loss by unlawful means of ) “wrongful loss” means the loss by unlawful means of property to which the person losing is legally entitled.property to which the person losing is legally entitled.


Restrictions on giving of loans by Restrictions on giving of loans by company for purchase of its shares: company for purchase of its shares:

[S 67(2)][S 67(2)] ((22) No public company shall give, whether ) No public company shall give, whether

directly or indirectly and whether by means of a directly or indirectly and whether by means of a loan, guarantee, the provision of security or loan, guarantee, the provision of security or otherwise, any financial assistance for the otherwise, any financial assistance for the purpose ofpurpose of, or in connection with, a , or in connection with, a purchase or purchase or subscription made subscription made or to be made, by any person or to be made, by any person of or of or for any shares for any shares in the company or in its in the company or in its holding company.holding company.

((33) Nothing in sub-section () Nothing in sub-section (22) shall apply to— ) shall apply to— (a) (a) the lending of money by a banking company in the lending of money by a banking company in the ordinary course of its business; … the ordinary course of its business; …


Prohibition for buy-back in certain Prohibition for buy-back in certain circumstances: (S 70)circumstances: (S 70)

((11) No company shall directly or indirectly purchase its ) No company shall directly or indirectly purchase its own shares or other specified securities—own shares or other specified securities—

(a) ….(a) ….(b) ….(b) ….((cc) ) if a defaultif a default, , is made by the companyis made by the company, , in repayment of in repayment of

any term loan or interest payable thereon to any any term loan or interest payable thereon to any financial institution or banking companyfinancial institution or banking company: Provided that : Provided that the buy-back is not prohibited, if the default is the buy-back is not prohibited, if the default is remedied and a period of three years has lapsed after remedied and a period of three years has lapsed after such default ceased to subsist.such default ceased to subsist.

So, if there is a default in payment of a credit facility to a So, if there is a default in payment of a credit facility to a bank, a company is prohibited from doing any buyback bank, a company is prohibited from doing any buyback of shares (S 70).of shares (S 70).


Prohibition on acceptance of Prohibition on acceptance of deposits from publicdeposits from public: (S 73): (S 73)

((11) On and after the commencement of this Act, no ) On and after the commencement of this Act, no company shall invite, accept or renew deposits company shall invite, accept or renew deposits under this Act from the public except in a manner under this Act from the public except in a manner provided under this Chapter:provided under this Chapter:

Provided that Provided that nothing in this sub-section shall apply to nothing in this sub-section shall apply to a banking company a banking company and NBFC as defined in the RBI and NBFC as defined in the RBI Act, 1934 and to such other company as the Central Act, 1934 and to such other company as the Central Government may, after consultation with the Government may, after consultation with the Reserve Bank of India, specify in this behalf.Reserve Bank of India, specify in this behalf.


Financial Statement [S 129(1)]:Financial Statement [S 129(1)]:

The financial statements shall give a true and fair view The financial statements shall give a true and fair view of the state of affairs of the company or companies, of the state of affairs of the company or companies, comply with the accounting standards comply with the accounting standards notified under notified under section 133 section 133 and shall be in the form or forms as may and shall be in the form or forms as may be provided for different class or classes of be provided for different class or classes of companies in Schedule IIIcompanies in Schedule III: Provided that the items : Provided that the items contained in such financial statements shall be in contained in such financial statements shall be in accordance with the accounting standards: Provided accordance with the accounting standards: Provided further that further that nothing contained in this sub-section nothing contained in this sub-section shall apply to any insurance or banking company ….shall apply to any insurance or banking company ….: : (since, it would be in the form and manner required (since, it would be in the form and manner required under the Banking Regulation Act). under the Banking Regulation Act).


Powers of the Board u/s 179Powers of the Board u/s 179 The Board of Directors of a company shall exercise the The Board of Directors of a company shall exercise the

following powers on behalf of the company by means of following powers on behalf of the company by means of resolutions passed resolutions passed at meetings of the Boardat meetings of the Board, namely:— , namely:— … …

((dd) ) to borrow moniesto borrow monies; ; ((ff) ) to grant loans or give guarantee or provide security to grant loans or give guarantee or provide security

in respect of loansin respect of loans; ; Provided that the Board may, by a resolution passed at Provided that the Board may, by a resolution passed at

a meeting, a meeting, delegate delegate to any committee of directors, the to any committee of directors, the managing director, the manager or any other principal managing director, the manager or any other principal officer of the company or in the case of a branch office officer of the company or in the case of a branch office of the company, the principal officer of the branch of the company, the principal officer of the branch office, the powers specified in clauses (office, the powers specified in clauses (dd) to () to (ff) on such ) on such conditions as it may specify: conditions as it may specify:


Cont..Cont.. Provided further that the Provided further that the acceptance by a banking acceptance by a banking

company in the ordinary course of its business of company in the ordinary course of its business of deposits of money from the public deposits of money from the public repayable on repayable on demand or otherwise and withdrawable by cheque, demand or otherwise and withdrawable by cheque, draft, order or otherwise, draft, order or otherwise, or the placing of monies on or the placing of monies on deposit by a banking company with another banking deposit by a banking company with another banking companycompany on such conditions as the Board may on such conditions as the Board may prescribe, prescribe, shall not be deemed to be a borrowing shall not be deemed to be a borrowing of of monies monies oror, as the case may be, , as the case may be, a making of loans a making of loans by a by a banking company within the meaning of this section.banking company within the meaning of this section.

Explanation IExplanation I.—Nothing in clause (.—Nothing in clause (dd) shall apply to ) shall apply to borrowings by a banking company from other banking borrowings by a banking company from other banking companies or from the RBI, the SBI or any other banks companies or from the RBI, the SBI or any other banks established by or under any Act.established by or under any Act.


Restrictions on powers of Board: (S Restrictions on powers of Board: (S 180) (previously O.R., now S.R.)180) (previously O.R., now S.R.)

((11) The Board of Directors of a company shall exercise ) The Board of Directors of a company shall exercise the following powers only with the consent of the the following powers only with the consent of the company by a company by a special resolutionspecial resolution, namely:— , namely:—

((aa) to sell, lease or otherwise dispose of the whole or ) to sell, lease or otherwise dispose of the whole or substantially the whole of the undertaking of the substantially the whole of the undertaking of the company or where the company owns more than one company or where the company owns more than one undertaking, of the whole or substantially the whole of undertaking, of the whole or substantially the whole of any of such undertakings.any of such undertakings.

ExplanationExplanation.—(.—(ii) “undertaking” shall mean an undertaking in which the ) “undertaking” shall mean an undertaking in which the investment of the company exceeds 20% of its net worth as per the investment of the company exceeds 20% of its net worth as per the audited balance sheet of the preceding financial year or an undertaking audited balance sheet of the preceding financial year or an undertaking which generates 20% of the total income of the company during the which generates 20% of the total income of the company during the previous financial year; (previous financial year; (iiii) “substantially the whole of the undertaking” ) “substantially the whole of the undertaking” in any financial year shall mean 20% or more of the value of the in any financial year shall mean 20% or more of the value of the undertaking as per the audited balance sheet of the preceding financial undertaking as per the audited balance sheet of the preceding financial year;year;


Cont.. Cont.. ((cc) to borrow money, where the money to be ) to borrow money, where the money to be

borrowed, together with the money already borrowed borrowed, together with the money already borrowed by the company will by the company will exceed aggregate of its paid-exceed aggregate of its paid-up share capital and free reservesup share capital and free reserves, , apart from apart from temporary loans obtained from the company’s temporary loans obtained from the company’s bankers in the ordinary course of businessbankers in the ordinary course of business: :

Provided that the Provided that the acceptance by a banking company, in acceptance by a banking company, in the ordinary course of its business, of deposits of the ordinary course of its business, of deposits of money from the publicmoney from the public, repayable on demand or , repayable on demand or otherwise, and withdrawable by cheque, draft, order otherwise, and withdrawable by cheque, draft, order or otherwise, or otherwise, shall not be deemed to be a borrowing shall not be deemed to be a borrowing of monies by the banking company within the of monies by the banking company within the meaning of this clause.meaning of this clause.


Cont.. Cont.. ExplanationExplanation.—the expression “temporary loans” means .—the expression “temporary loans” means

loans loans repayable on demand or within six months repayable on demand or within six months from the from the date of the loan such as short-term, cash credit date of the loan such as short-term, cash credit arrangements, the discounting of bills and the issue of arrangements, the discounting of bills and the issue of other short-term loans of a seasonal character, other short-term loans of a seasonal character, but does but does not include loans raised for the purpose of financial not include loans raised for the purpose of financial expenditure of a capital natureexpenditure of a capital nature;;

By By MCA General Circular No. 4/2014, it has clarified that , it has clarified that “the resolution passed u/s 293 of the old Act prior to “the resolution passed u/s 293 of the old Act prior to 12.09.2013 with reference to borrowings (subject to the 12.09.2013 with reference to borrowings (subject to the limits prescribed) and / or creation of security on assets of limits prescribed) and / or creation of security on assets of the company will be regarded as sufficient compliance of the company will be regarded as sufficient compliance of the requirements of S 180 of the new Act for a period of 1 the requirements of S 180 of the new Act for a period of 1 year from the date of notification of S 180 of the Act.” year from the date of notification of S 180 of the Act.”

S 293 was applicable to Public company, now S 180 is S 293 was applicable to Public company, now S 180 is applicable to private companies as well. applicable to private companies as well.


Loans to Director etc (S 185)Loans to Director etc (S 185) ((11) Save as otherwise provided in this Act, no ) Save as otherwise provided in this Act, no

company shall, directly or indirectly, company shall, directly or indirectly, advance any advance any loanloan, including any loan represented by a book debt, , including any loan represented by a book debt, to any of its directorsto any of its directors oror to any other PERSON in to any other PERSON in whom the director is interestedwhom the director is interested or or give any give any guarantee or provide any security guarantee or provide any security in connection in connection with any loan taken by him or such other personwith any loan taken by him or such other person: :

Provided that nothing contained in this sub-section Provided that nothing contained in this sub-section shall apply to— shall apply to—

((aa) the giving of any loan to a managing or whole-) the giving of any loan to a managing or whole-time director— (time director— (ii) as a part of the conditions of ) as a part of the conditions of service extended by the company to all its service extended by the company to all its employees; or (employees; or (iiii) pursuant to any scheme approved ) pursuant to any scheme approved by the members by a special resolution; or by the members by a special resolution; or


Cont.. Cont.. ((bb) a company which in the ordinary course of its ) a company which in the ordinary course of its

business provides loans or gives guarantees or business provides loans or gives guarantees or securities for the due repayment of any loan and in securities for the due repayment of any loan and in respect of such loans an interest is charged at a rate respect of such loans an interest is charged at a rate not less than the bank rate declared by the Reserve not less than the bank rate declared by the Reserve Bank of India.Bank of India.

Explanation.Explanation.—For the purposes of this section, the —For the purposes of this section, the expression “to any other person in whom director is expression “to any other person in whom director is interested” means—interested” means—

((aa) any director of the lending company, or of a company ) any director of the lending company, or of a company which is its holding company or any partner or relative which is its holding company or any partner or relative of any such director; of any such director;

((bb) any firm in which any such director or relative is a ) any firm in which any such director or relative is a partner; partner;


Cont. Cont. ((cc) any private company of which any such director is ) any private company of which any such director is

a director or member; a director or member; ((dd) any ) any body corporate body corporate at a general meeting of which at a general meeting of which

not less than 25% of the total voting power may be not less than 25% of the total voting power may be exercised or controlled by any such director, or by exercised or controlled by any such director, or by two or more such directors, together; ortwo or more such directors, together; or

((ee) ) any body corporate, the Board of directors, any body corporate, the Board of directors, managing director or manager, whereof is managing director or manager, whereof is accustomed to act in accordance with the directions accustomed to act in accordance with the directions or instructions of the Board, or of any director or or instructions of the Board, or of any director or directors, of the lending companydirectors, of the lending company..


Penalties: [S 185(2)]Penalties: [S 185(2)] If any loan is advanced or a guarantee or security is If any loan is advanced or a guarantee or security is

given or provided in contravention of the provisions of given or provided in contravention of the provisions of sub-section (1), the company shall be punishable sub-section (1), the company shall be punishable with fine which shall not be with fine which shall not be less than five lakhless than five lakh rupees rupees but which may extend to but which may extend to twenty-five lakh rupeestwenty-five lakh rupees,,

and the director or the other person to whom any loan and the director or the other person to whom any loan is advanced or guarantee or security is given or is advanced or guarantee or security is given or provided in connection with any loan taken by him or provided in connection with any loan taken by him or the other person, shall be punishable with the other person, shall be punishable with imprisonment imprisonment which may extend to which may extend to six monthssix months or or with with finefine which shall not be which shall not be less than five lakh less than five lakh rupeesrupees but which may extend to but which may extend to twenty-five lakh twenty-five lakh rupees, or with both.rupees, or with both.


Finally, exemption granted under Finally, exemption granted under Rules: [RuleRules: [Rule 10; Chapter 12]10; Chapter 12]

(1) Any (1) Any loan loan made by a made by a holding company to its WOS holding company to its WOS or any or any guarantee given or security provided guarantee given or security provided by a by a holding company in respect of any loan made to its holding company in respect of any loan made to its WOS company is exempted from the requirements of WOS company is exempted from the requirements of S 185; andS 185; and

(2) Any (2) Any guarantee given or security provided guarantee given or security provided by a by a holding company in respect of loan made by any holding company in respect of loan made by any bank or financial institution to its subsidiary bank or financial institution to its subsidiary company company is exempted from the requirements under is exempted from the requirements under this section: this section: Provided that such loans made under Provided that such loans made under sub-rule(1) and (2) are utilised by the subsidiary sub-rule(1) and (2) are utilised by the subsidiary company for its principle business activitiescompany for its principle business activities..


Inter-corporate Loan & Investment by Inter-corporate Loan & Investment by the Companies: (S 186)the Companies: (S 186)

((11) A company may make investment through not more ) A company may make investment through not more than two layers of investment companies:than two layers of investment companies:

Provided that the provisions of this sub-section shall not Provided that the provisions of this sub-section shall not affect,—affect,—

((ii) ) a company from acquiring any other company a company from acquiring any other company incorporated in a country outside India if such other incorporated in a country outside India if such other company has investment subsidiaries beyond two layers company has investment subsidiaries beyond two layers as per the laws of such country;as per the laws of such country;

((iiii) ) a subsidiary company from having any investment a subsidiary company from having any investment subsidiary for the purposes of meeting the requirements subsidiary for the purposes of meeting the requirements under any law or under any rule or regulation framed under any law or under any rule or regulation framed under any law for the time being in force.under any law for the time being in force.


Relevant portion of S 186 In Relevant portion of S 186 In Nutshell-Nutshell-

No company shall directly or indirectly give any loan No company shall directly or indirectly give any loan to any other person or body corporate exceeding to any other person or body corporate exceeding 60% of its paid up share capital, free reserves and 60% of its paid up share capital, free reserves and share premium or 100% of its free reserves and share premium or 100% of its free reserves and securities premium whichever is more.securities premium whichever is more.

If the company proposes to advance any such loan If the company proposes to advance any such loan exceeding its limits then prior approval by means of exceeding its limits then prior approval by means of a special resolution passed at a general meeting a special resolution passed at a general meeting shall be required. shall be required.

Prior approval of the public financial institution shall Prior approval of the public financial institution shall also be required if there is any default in repayment also be required if there is any default in repayment of instalment or interest on the term loan.of instalment or interest on the term loan.


Cont.. Cont.. ((1111) Nothing contained in S 186, except sub-section ) Nothing contained in S 186, except sub-section

((11), shall apply— ), shall apply— ((aa) to a ) to a loan made, guarantee given or security loan made, guarantee given or security

provided by a banking company provided by a banking company or an insurance or an insurance company or a housing finance company company or a housing finance company in the in the ordinary course of its business ordinary course of its business or a company or a company engaged in the business of financing of companies engaged in the business of financing of companies or of providing infrastructural facilities; or of providing infrastructural facilities;


Investments of company to be Investments of company to be held in its own name: (S 187)held in its own name: (S 187)

((11) All investments made or held by a company in ) All investments made or held by a company in any any propertyproperty, , security security or or other asset other asset shall be made shall be made and held by it in its own name:and held by it in its own name:

((22) Nothing in this section shall be deemed to ) Nothing in this section shall be deemed to prevent a company— (prevent a company— (aa) from ) from depositing with a depositing with a bankbank, being the bankers of the company, , being the bankers of the company, any any shares or securities shares or securities for the collection of any for the collection of any dividend or interest payable thereon; or (dividend or interest payable thereon; or (bb) from ) from depositing with, or transferring to, or holding in the depositing with, or transferring to, or holding in the name of, the SBI or a scheduled bank, being the name of, the SBI or a scheduled bank, being the bankers of the company, shares or securities, in bankers of the company, shares or securities, in order to facilitate the transfer thereof:order to facilitate the transfer thereof:


Cont.. Cont.. Provided that if within a period of six months from the Provided that if within a period of six months from the

date on which the shares or securities are transferred by date on which the shares or securities are transferred by the company to, or are first held by the company in the the company to, or are first held by the company in the name of, the SBI or a scheduled bank as aforesaid, no name of, the SBI or a scheduled bank as aforesaid, no transfer of such shares or securities takes place, the transfer of such shares or securities takes place, the company shall, as soon as practicable after the expiry of company shall, as soon as practicable after the expiry of that period, have the shares or securities re-transferred that period, have the shares or securities re-transferred to it from the SBI or the scheduled bank or, as the case to it from the SBI or the scheduled bank or, as the case may be, again hold the shares or securities in its own may be, again hold the shares or securities in its own name; or (name; or (cc) ) from depositing with, or transferring to, any from depositing with, or transferring to, any person any shares or securities, by way of security for person any shares or securities, by way of security for the repayment of any loan advanced to the company or the repayment of any loan advanced to the company or the performance of any obligation undertaken by itthe performance of any obligation undertaken by it ; (; (dd) ) from holding investments in the name of a depository from holding investments in the name of a depository when such investments are in the form of securities held when such investments are in the form of securities held by the company as a beneficial ownerby the company as a beneficial owner. .


Other ImplicationsOther Implications

Provisions relating to class action u/s 245 of the Provisions relating to class action u/s 245 of the Companies Act, 2013 do not apply to Banking Companies Act, 2013 do not apply to Banking companies. companies.

If a Company defaults in repayment of loan to the Banks- If a Company defaults in repayment of loan to the Banks- A.A. The Company can not issue shares with differential The Company can not issue shares with differential

voting rights. (Rule 4; Chapter 4).voting rights. (Rule 4; Chapter 4). B. The Company can not buy back its own shares (Rule B. The Company can not buy back its own shares (Rule

17; Chapter 4). [17; Chapter 4). [NoteNote: The company can not utilize any : The company can not utilize any money borrowed from banks or financial institutions for money borrowed from banks or financial institutions for the purpose of buying back its shares.]the purpose of buying back its shares.]

C. Company needs to take consent of the respective C. Company needs to take consent of the respective Banks before making any inter-corporate loan, Banks before making any inter-corporate loan, investment or giving any guarantee/ security for any investment or giving any guarantee/ security for any person. (S 186)person. (S 186)


Other implicationsOther implications Companies is required to appoint internal auditor if, Companies is required to appoint internal auditor if,

outstanding loans from banks/ public financial outstanding loans from banks/ public financial institutions exceeding Rs. 100 crore or more at any institutions exceeding Rs. 100 crore or more at any point of time during the preceding financial year: (Rule point of time during the preceding financial year: (Rule 13; Chapter 9)13; Chapter 9)

Every listed companies which have borrowed money Every listed companies which have borrowed money from banks and public financial institutions in excess of from banks and public financial institutions in excess of fifty crore rupees needs to establish a vigil mechanism fifty crore rupees needs to establish a vigil mechanism (Rule 7; Chapter 12).(Rule 7; Chapter 12).

The provisions for appointment of nominee directors, as The provisions for appointment of nominee directors, as a part of lending contracts, now also extends to NBFCs, a part of lending contracts, now also extends to NBFCs, if the requisite power is there in the loan agreement. if the requisite power is there in the loan agreement. That is to say, where the loan agreement empowers, an That is to say, where the loan agreement empowers, an NBFC may appoint its nominee on the board of the NBFC may appoint its nominee on the board of the borrower company.borrower company.


Bank should also be very cautious about dealings Bank should also be very cautious about dealings with various issues pertaining to the Related Party with various issues pertaining to the Related Party Transactions(S 188), Disclosure of interest (S 184), Transactions(S 188), Disclosure of interest (S 184), dealings with cross holdings, JVs, or holding –dealings with cross holdings, JVs, or holding –subsidiary relations. subsidiary relations.

Must make most suitable Corporate Governance Must make most suitable Corporate Governance Structure in line with the compliance of applicable Structure in line with the compliance of applicable laws (including RBI Guidelines on the same)laws (including RBI Guidelines on the same). .


Corporate Legal Practice

““A journey of a thousand miles A journey of a thousand miles begins with a single step.”begins with a single step.”

BY:BY:HARSHUL SHAHHARSHUL SHAH

ADVOCATE & SOLICITORADVOCATE & SOLICITORMob: +91 9867129866/ Tel: +91 022 26840267Mob: +91 9867129866/ Tel: +91 022 26840267

Email: Email: [email protected]: https://www.facebook.com/harshul1979Facebook: https://www.facebook.com/harshul1979

05/01/23

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New Companies Act, 2013- implications on banks