PAS-3 — Return of Allotment

PAS-3 is the e-form that reports every allotment of securities to the Registrar of Companies — equity shares, preference shares, debentures on conversion, ESOP exercises, bonus issues. The filing window is 30 days from the date of allotment (the board resolution date, not the date the certificate is printed), and it must attach the list of allottees, the valuation report where Section 62(1)(c) or Rule 11UA applies, and the board resolution.

A late PAS-3 does not undo the allotment but exposes the company and every officer in default to penalty under Section 450, and a diligence buyer's counsel will flag every gap between an allotment date on the cap table and its corresponding PAS-3 filing date as an open compliance item. Saral's ledger records the allotment event and the filing event separately, so the gap — and any that are still open — is visible without reconstructing it from the MCA portal.

Multiple allotments on the same date to different allottees can be combined in a single PAS-3; allotments on different dates cannot, even to the same class of security.

The cap table, where PAS-3 — Return of Allotment appears as a computed field traced to the ledger event that created it.