MCA has examined the matter and vide General Circular No. 28/2020, dated 17/08/2020 has clarified that the companies which are unable to hold their AGM for the financial year ended on 31/03/2020 should file their applications in form no. GNL-1 for seeking extension of time for holding AGM for the financial year ended on 31/03/2020 with the concerned Registrar of Companies on or before 29/09/2020 but Companies need not wait for the last date of Sept. 29 stipulated by MCA to file the request as the approval if denied would culminate into a long-drawn process of compounding penalty for the companies.

Proviso to section 96(1) provides that the Registrar may, for any special reason, extend the time within which any annual general meeting, other than the first annual general meeting, shall be held, by a period not exceeding three months.