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It is stated, by referring to Section 129(1) read
with Section 129(2) of the Companies Act, 2013,
that the standalone financial statement/
standalone balance sheet of the petitioner
company as prepared and filed is considered as its
balance sheet and consolidated balance sheet is
not considered as the balance sheet of the
petitioner company. Preparation and filing of the
consolidated financial statement is in addition to
the standalone financial statement, hence the
provisions of Section 129(3) of the Companies Act,
Patna High Court CWJC No.208 of 2020 dt.11-08-2022
2013 can, in no manner, be interpreted so as to
mean that the Respondent No. 2 is entitled to
consider the consolidated financial statements of
the petitioner (as opposed to its standalone
financial statements) in order to evaluate and
determine eligibility of the petitioner under Clause
4.5(D) of the NIT. It is stated that it is a well settled
legal position, settled by a catena of judicial
precedents, that a company is a separate and
distinct legal entity from its subsidiaries having
independent corporate personality. Reference has
also been made to Section 19 of the Companies
Act, which substantively bars a subsidiary
company from holding shares in its holding
company either by itself or through its nominees,
and furthermore bars a holding company from
allotting or transferring its shares to any of its
subsidiary companies, and expressly declares any
such allotment or transfer of shares of a company
to its subsidiary company to be void. Thus, it is
submitted that the clear legislative intent is to
maintain separate operational identity of a holding
Patna High Court CWJC No.208 of 2020 dt.11-08-2022
company and its subsidiaries and thereby preserve
the respective shareholders' control over them. It
is also submitted that Section 129 of the
Companies Act, 2013 is merely a compliance
requirement & an extension of Section 212 of the
Companies Act, 1956 for providing information
about the group of companies. In this regard, the
learned counsel for the petitioner has referred to a
judgment rendered by the Hon'ble Apex Court in
the case of State of Kerala vs. Zoom
Developers (P) Ltd. & Others, reported in
(2009) 4 SCC 563, paragraph no. 31 whereof is
reproduced herein below:-