---
title: "Who owns this company? What the annual return shows about shareholding, and what it hides"
description: "Shareholding in an Indian private company is public, once a year, in an attachment to the annual return. Here is where to find it and the three things it will not tell you."
author: "Pradeep Vanga"
published: 2026-09-11
updated: 2026-09-11
category: "Guide"
tags: ["shareholding", "annual-return", "ownership", "mgt-7"]
canonical: https://entiva.in/blog/who-owns-a-private-company-india/
publisher: "Entiva"
---

# Who owns this company? What the annual return shows about shareholding, and what it hides

"Private limited" sounds like the ownership is private. In India it is not.

Every company on the register files an annual return, and attached to it is a
list of who held the shares. Names, and how many each one held. It is public,
it costs ₹100 to retrieve, and most people who want it never find it because
they are looking for a field on a web page rather than an attachment inside a
PDF.

Here is where it actually lives, and, more usefully, the three large holes in
it that nobody warns you about.

## The annual return is the document

Section 92 of the Companies Act 2013 requires every company to file an annual
return. It is a snapshot of the company as at the close of its financial year,
and among the things it has to record are the company's shareholding and its
members.

The form depends on the company's size. Most companies file **Form MGT-7**. A
one person company or a small company files an abridged version, **Form
MGT-7A**, introduced from the financial year 2020-21 by the Companies
(Management and Administration) Amendment Rules 2021, notified on 5 March 2021.
If the company you are looking at is small, expect MGT-7A and expect it to be
shorter.

The part you want is not in the form body. It is an **attachment**.

## What the filing actually looks like

Here is the document list for one small private company, in the category
"Annual Returns and Balance Sheet eForms", exactly as the registry lists it:

| Date filed | Form | Attachment | Pages |
| --- | --- | --- | --- |
| 28/01/2025 | MGT-7A | Form MGT-7A | 13 |
| 28/01/2025 | MGT-7A | List of Directors | 1 |
| 28/01/2025 | MGT-7A | **List of share holders, debenture holders** | 1 |
| 28/01/2026 | AOC-4 | Copy of Financial Statements | 26 |
| 28/01/2026 | MGT-7A | Form MGT-7A | 15 |
| 28/01/2026 | MGT-7A | **List of share holders, debenture holders** | 1 |

There it is, twice, once for each year, and it is one page long.

That is the thing to internalise. **The shareholder list is a separate
attachment with its own row**, and if you retrieve only the main form you will
have thirteen pages telling you almost everything about the company except who
owns it. People pay the fee, open the wrong file, and conclude the information
is not public.

For a small company that page will typically carry each shareholder's name, the
number of shares held, and the class. That is enough to answer "who owns this",
"in what proportion", and "did that change since last year".

We do not reproduce shareholder names in our writing, because a filing that
happens to be public is still somebody's personal information and republishing
it into a search index is a different act from letting a reader look it up. The
point here is the mechanism, not any particular company's owners.

## Hole one: it is a once-a-year photograph

The annual return describes the company as at the close of its financial year.
Not today. Not when you retrieve it.

Work through the timing and it gets worse than it sounds. The financial year
ends on 31 March. The annual general meeting can be held as late as 30
September. The annual return follows within sixty days of that meeting. So a
return filed in late November describes a company as it stood eight months
earlier, and the next one is a year behind that.

**The practical consequence:** the shareholder list you are reading can easily
be eighteen months out of date by the time it answers your question. Always
read the "as at" date, and always say it out loud when you quote the figure to
someone else.

## Hole two: share transfers are invisible until the next return

This is the one that surprises people, and it is the most important thing on
this page.

When shares in a private company change hands, the transfer is executed on
**Form SH-4**, delivered to the company, approved by the board, and entered in
the company's own **register of members** under section 88. All of that happens
inside the company.

**None of it is filed with the registrar at the time.** There is no event
filing for an ordinary share transfer. The registrar finds out the way you do:
in the next annual return.

So a private company can change hands entirely in April and the public record
will show the old owners until the following year's MGT-7 is filed. If your
question is "who owns this company *now*", the honest answer from the register
is "here is who owned it at the last financial year end, and I cannot tell you
whether that is still true".

There is one useful exception. If the company **issued new shares** rather than
transferring existing ones, that is an allotment, and a return of allotment on
**Form PAS-3** goes to the registrar as an event filing. So new capital coming
in is visible between annual returns. Ownership quietly changing hands is not.

## Hole three: a corporate shareholder is a wall, not an answer

Very often the shareholder list names another company. Which tells you nothing,
except where to look next.

Two routes through it.

**Trace it.** The corporate shareholder has its own CIN, its own annual return,
and its own list of shareholders. Repeat until you reach human beings or run
out of patience. This works and it is tedious, and it is the actual method
behind most ownership research on Indian companies.

**Look for a BEN-2.** Section 90 of the Companies Act 2013 creates the concept
of a **significant beneficial owner**, and the threshold everyone quotes is not
in the section. Section 90(1) itself says "not less than twenty-five per cent.
or such other percentage as may be prescribed". The prescribed figure is
**10%**, and it lives in rule 2(1)(h) of the Companies (Significant Beneficial
Owners) Rules 2018, as substituted in February 2019.

Then there is a catch that most write-ups miss. The rule's Explanation I says
that if an individual "does not hold any right or entitlement indirectly", they
are not a significant beneficial owner at all. **So somebody holding 40%
directly and nothing indirectly is not an SBO**, and no BEN filing is triggered
by them. The regime is aimed at ownership held through layers, not at
ownership held in the open.

Where it does apply, the individual declares on **Form BEN-1**, and the company
reports to the registrar on **Form BEN-2** within thirty days of receiving the
declaration. The company also keeps a register on Form BEN-3, and can compel
disclosure by serving Form BEN-4.

A BEN-2 on the file is a short cut straight to the person. **The absence of one
proves nothing**, because it may mean there is no significant beneficial owner
to report, or it may mean nobody filed. Treat a BEN-2 as a gift when it is
there and never as a guarantee when it is not.

There is a related layer worth knowing about. Under section 89, where the
registered holder of shares is not the beneficial owner, both are supposed to
declare it and the company files Form MGT-6. It is the nominee-shareholding
disclosure, and like BEN-2 it is only as good as the filing behind it.

## What you get for free, before paying anything

Not the shareholders. But two adjacent numbers are in the free master data on
the MCA portal, and they are worth reading first:

- **Authorised capital**, the ceiling on shares the company may issue. It is a
  number the company chose, and it says almost nothing about the business.
- **Paid-up capital**, what shareholders have actually put in. This is the
  meaningful one, and a company with ₹1 lakh of paid-up capital and a ₹40 crore
  contract is a shape worth thinking about.

Confirm you have the right entity by [its CIN](https://entiva.in/blog/how-to-read-a-cin-number/)
while you are there. Group companies with near-identical names are common, and
ownership questions are exactly where people end up reading the wrong file.

## How to actually do it

1. **Find the company and note its CIN.** Free.
2. **Read paid-up capital** in the master data. Free, and it frames everything
   that follows.
3. **Retrieve the "Annual Returns and Balance Sheet eForms" category** from
   View Public Documents. One fee, ₹100, covers the company, and it is one of
   [the eight categories a retrieval covers](https://entiva.in/what-you-can-find/). The
   [full route through the portal](https://entiva.in/blog/how-to-download-mca-documents/) has
   four constraints worth knowing before you start.
4. **Open the attachment named "List of share holders, debenture holders"**,
   not the main form. Do this for the two or three most recent years.
5. **Compare years.** A shareholder who appears, disappears, or changes size
   between two returns is the interesting part. One return is a fact; two are a
   story.
6. **Check for PAS-3 and BEN-2** in the other eForm categories. New capital and
   declared beneficial owners both live outside the annual return.
7. **Write down the "as at" date** next to whatever you conclude.

## What none of this settles

**Not who controls the company.** Shareholding and control are different
things. Control can sit in the articles, in a shareholders' agreement that is
never filed, in a lender's covenants, or in who the directors actually listen
to. The register sees none of it.

**Not what the shares are worth.** The annual return records numbers of shares,
not valuations.

**Not whether the list is complete or correct.** The registrar receives
filings; it does not audit them.

**And not anything at all if the company simply has not filed.** A company that
skipped its last two annual returns has no recent shareholder list to retrieve,
and that absence is itself worth noticing. If you are looking at ownership
because money is at stake, read the
[filing history alongside it](https://entiva.in/blog/how-to-find-a-private-company-revenue-india/).

Ownership research on Indian private companies is genuinely doable, and it is
the register at its most useful. It is just an attachment rather than a field,
a year late rather than live, and one company deep rather than all the way
down. Knowing those three things in advance is most of the skill.

*Written by the Entiva team, who read Indian company filings for a living. Not
legal or investment advice.*

## Frequently asked

### Is the shareholding of a private limited company in India public?

Yes, once a year. Every company files an annual return, Form MGT-7 or the abridged MGT-7A for one person companies and small companies, and the list of shareholders and debenture holders is an attachment to it. Anyone can retrieve it from the MCA portal for the ₹100 inspection fee.

### Will the annual return show share transfers during the year?

No. A share transfer in a private company is executed on Form SH-4 and entered in the company's own register of members. It is not filed with the registrar when it happens. It only becomes visible in the next annual return, which may be more than a year later.

### How do I find the real owner behind a corporate shareholder?

Look for a Form BEN-2 filing. Section 90 of the Companies Act 2013 creates the significant beneficial owner regime, and the 10% threshold is prescribed by rule 2(1)(h) of the Companies (Significant Beneficial Owners) Rules 2018 rather than by the section, which says 25% or such other percentage as may be prescribed. The holding must be indirect: Explanation I to that rule excludes a person whose entire holding is direct. The individual declares on BEN-1 and the company files BEN-2. Where no BEN-2 exists, you have to trace the corporate shareholder's own annual return.

## Related reading

- [How to download a company's documents from the MCA portal, and what it actually costs you](https://entiva.in/blog/how-to-download-mca-documents/): The MCA charges ₹100 to see a company's filings. Here is the full route through View Public Documents, the four limits nobody warns you about, and when it is worth it.
- [How to find out what a private Indian company earns](https://entiva.in/blog/how-to-find-a-private-company-revenue-india/): Private Indian companies don't publish their accounts, but they do file them. Here's where the revenue figure actually sits, and how far to trust it.
- [How to read a CIN: what those 21 characters tell you](https://entiva.in/blog/how-to-read-a-cin-number/): A Corporate Identity Number isn't a random string. Each block of it tells you something real about a company, before you open a single filing.

_Published by Entiva (https://entiva.in/), which retrieves documents from the Ministry of Corporate Affairs' View Public Documents service on a customer's behalf. Entiva is not affiliated with the Ministry of Corporate Affairs and does not resell another provider's database. Free lookups use MCA company master data._