Company · Annual rhythm
We owe money to MSME suppliers — what's this half-yearly return?
The short answer
If your company owes micro or small suppliers beyond 45 days of acceptance, you must file MSME-1 with the ROC for each half-year. The return for April–September is due by 31 October; the October–March period is due by 30 April. Section 405 of the Companies Act and Section 15 of the MSMED Act drive this — and the parallel income-tax bite under s.43B(h), Income Tax Act 1961 (for tax years before 1 Apr 2026), or s.37(2)(g), Income-tax Act 2025 (from tax year 2026-27), can disallow those dues in your return.
The sequence
- 1Identify dues to micro and small suppliers still outstanding beyond 45 days of acceptance
- 2Compile supplier details and outstanding amounts for the relevant half-year window
- 3File MSME-1 on the MCA portal before the statutory deadline for that period
- 4Reconcile the filing with your books and flag any amounts at risk under s.43B(h), Income Tax Act 1961 (for tax years before 1 Apr 2026), or s.37(2)(g), Income-tax Act 2025 (from tax year 2026-27)
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Questions founders actually ask
When exactly is MSME-1 due?
For the half-year ending 30 September, file by 31 October. For the half-year ending 31 March, file by 30 April.
Which supplier dues count?
Amounts owed to micro and small enterprises that remain unpaid beyond 45 days from the date of acceptance of goods or services.
Does this affect our tax return?
Yes. s.43B(h), Income Tax Act 1961 (for tax years before 1 Apr 2026), and s.37(2)(g), Income-tax Act 2025 (from tax year 2026-27) can disallow deductions for MSME dues not paid within the prescribed period — use your tax forecaster to model the impact.
Reviewed by Harun Raaj, Chartered Accountant
Founder, Harun Raaj & Associates. Last verified 2026-08-24 against MCA V3 records and ICSI reference material. Form-level deadlines and penalties live on the linked form pages and update there.