How to know who invested in a private company

Allotment is when a company assigns newly issued shares or other securities to particular people or entities. Those recipients are the allottees. PAS-3, commonly called the return of allotment, reports this to the Registrar of Companies.

For example, a company issues 10,000 new shares to an investor. PAS-3 records the allotment; the allottee list identifies the recipient and their allocation.

An investor can put money into a company in two ways, and MCA shows them very differently.

So if someone appears in a shareholder list with no PAS-3 in their name, they most likely bought existing shares, or received them some other way, such as by inheritance.

One PAS-3 can contain multiple allotments. Read every relevant section and match each one to its allottee list. Counting PDFs will not tell you how many funding rounds took place.

You need an MCA login, the company’s CIN and ₹100 for access to its public documents.

1. Log in to mca.gov.in. Open MCA Services → Document Related Services → View Public Documents V3 → View Public Documents.

   

2. Find the company and pay ₹100. Search using its CIN, then open it from your Workspace.

   

3. Select the years and Other eForm Documents. Look for PAS-3 and its supporting documents. Widen the year range if an expected allotment is missing: it may have been filed later.

   

4. Download the form and attachments. Include the list of allottees and any relevant resolutions, contracts or valuation reports. Select up to five documents per batch, click Download, enter the captcha and submit.
5. Extract the zip and check inside the PDF. Supporting files may be separately listed or embedded in the form. Open the attachments panel using the paperclip icon in desktop Adobe Acrobat Reader.

The allottee list may be a PDF or spreadsheet. It can also be bundled with a resolution under an optional attachment label, so check the contents rather than relying only on filenames.

For older allotments, look for Form 2, the predecessor under the Companies Act, 1956. If an older form displays “Please wait” in your browser, try desktop Acrobat Reader.

Save the files within MCA’s access window. For payment and download problems, see the full MCA download guide.

Face value is the nominal value of a share. Premium is the amount charged above that value. They are different from the company’s valuation.

Suppose 10,000 shares with a face value of ₹10 are issued at a premium of ₹90 each, fully paid in cash:

• Issue price: ₹10 + ₹90 = ₹100 per share.
• Total subscription amount: 10,000 × ₹100 = ₹10 lakh.
• Increase in paid-up share capital: 10,000 × ₹10 = ₹1 lakh.
• Securities premium: 10,000 × ₹90 = ₹9 lakh.

This explains why a company’s paid-up capital can look small compared with the funding it raised. Premium is accounted for separately.

For partly paid shares, check the amount actually paid and what remains payable. Do not treat the full issue price as money already received. Compare the form’s totals with the allottee list; if they disagree, resolve the difference before relying on the amount.

No. Check how and why the securities were issued:

• Cash subscription: investors pay for the securities. Check the paid amounts.
• Bonus issue: existing shareholders receive additional shares without paying fresh money.
• Conversion: a loan, debenture or preference share converts into another security; the conversion itself may bring no new cash.
• Other non-cash consideration: shares may be issued for assets or a business instead of money.

A debenture allotment records debt securities, not an equity ownership percentage. Read any supporting contract or valuation report available for the transaction.

Dilution means an existing holder’s percentage falls as more shares are issued to others.

Suppose you own 100 of a company’s 1,000 identical, fully paid equity shares: 10%. If it issues 250 more to someone else, you still own 100, but out of 1,250: 8%.

PAS-3 supplies the new allotment, but you also need the starting share count and other changes. Preference rights, conversions and employee options can make the calculation more complex. Use the annual return and shareholder records to cross-check the ownership picture.

PAS-3 reports allotments. SH-7 reports specified alterations of share capital, such as an increase in authorised capital or a subdivision of shares.

Authorised capital is the company’s permitted nominal share-capital ceiling. Increasing it creates room for more shares; it does not prove that shares were issued or money was raised. An allotment within the existing ceiling need not require a fresh increase.

A share split changes the number and face value of shares without itself bringing in money. For example, one ₹10 share becomes ten ₹1 shares. This matters when comparing share counts and prices across years.

Read SH-7 alongside the capital clause in the company’s MOA.

ROCwork downloads selected years and categories from your logged-in MCA tab after you pay MCA’s fee. It checks zips, retries failed downloads and organises the files with an Excel index.

Collect PAS-3, its attachments and relevant annual returns together. Keep a timeline of allotment dates, recipients, security classes, quantities and prices. Check for duplicate copies before adding up totals.