Dealing with struck-off vendors and customers

Payments, recoveries, GST and the Schedule III disclosure: what finance and audit teams need to do when a counterparty has been struck off.

Why it matters

A struck-off company stands dissolved (section 248(5)). Under section 250 it can no longer operate as a company, except to realise amounts due to it and to pay its liabilities. Paying, buying from or selling to a struck-off company creates legal, tax and fraud risk, and listed and unlisted companies alike must disclose these relationships in their financial statements.

Schedule III: relationship with struck-off companies

Since financial year 2021-22, Schedule III to the Companies Act, 2013 requires companies to disclose transactions with companies struck off under section 248 or section 560 of the Companies Act, 1956. The disclosure is a table:

Name of struck-off companyNature of transactionsBalance outstandingRelationship, if any
Nature of transactions: investments in securities; receivables; payables; shares held by the struck-off company; other outstanding balances (to be specified).

To prepare it, screen the vendor master, customer master and shareholder register against the struck-off register at the year end, and keep the evidence (the STK-7 notice or MCA record) for each company you disclose.

Payments to a struck-off vendor

  • Pause new orders and payments until you have confirmed the status. Payments to a dissolved company, or to a bank account in its name, may be challenged and can signal fraud.
  • Ask about restoration. If the vendor says it is still trading, ask for the NCLT restoration order and the INC-28 filing, and confirm the status on the MCA portal. Restoration under section 252 →
  • Check who is invoicing. Directors sometimes continue the business through a new entity. Update the vendor master and contracts accordingly rather than paying the old company.

Recovering dues from a struck-off customer

Strike-off does not wipe out the company's liabilities. Under section 248(7) the liability of every director, officer and member continues and can be enforced as if the company had not been dissolved. A creditor can also apply to the NCLT under section 252(3) to restore the company in order to recover what it is owed.

GST

Check the vendor's GSTIN status on the GST portal as well as the MCA status. Input tax credit depends on the supplier being registered and filing its returns; credit on invoices from a supplier whose registration has been cancelled is at risk. A struck-off company's GST registration is usually cancelled, but not always at the same time, so check both.

A simple year-end routine

  1. Export the vendor, customer and investment masters with names and CINs.
  2. Screen them against the struck-off register. Struck-Off Company Check does a whole list at once and exports the matches to Excel.
  3. For each hit, confirm the current MCA status and look for a restoration order.
  4. Record the balances and transactions for the Schedule III table, and block the party in the ERP if appropriate.

Updated 19 October 2026. A general guide based on the Companies Act, 2013 and the Companies (Removal of Names of Companies from the Register of Companies) Rules, 2016, as amended. It is not legal advice; check the current text on the MCA website or with your professional adviser before acting.