The registered office address of a private company is usually different from the actual place of business. Registered office address for any communication is generally Director’s or counsel’s residence. Books of accounts of the company are generally kept at actual place of business.   It is to be noted that as per the provisions of the Companies Act, 2013, a company shall keep its books of accounts at its registered office itself. If a company maintains its books of accounts at any other place then the same should be reported to Roc in form AOC-5 Sec. 128 of the Companies Act, 2013 read with the Companies (Accounts) Rules, 2014 provides that:

• A company shall keep books of accounts, relevant books and papers and financial statements at its registered office only
• Books must be kept on accrual basis and according to double entry system of accounting
• It can be in hard copy or electronic mode
• In case of records in electronic mode, company shall intimate name of service provider, it’s IP address & location, address (if on cloud) to ROC on an annual basis at the time of filing of financial statement
• Any or all such accounting records may also be kept at any other place in India as decided by Board of Directors (BoD)
• Form AOC-5 must be filed mentioning the full address of place within 7 days of decision made by BoD to keep the books of accounts at any other place in India along with the copy of board resolution as an attachment.
• In case of Branches (in or outside India), books can be kept at branch office provided summarized returns are sent to the registered office at regular intervals (On a quarterly basis in case of Foreign Branches based outside India)
• Books alongwith vouchers must be kept in good order for 8 years immediately preceding the relevant year.

  Penalty for non-compliance of above provision

• MD/WTD/CFO/Other responsible person can be imprisoned for a period upto 1 year, or
• Minimum fine of INR 50,000, maximum INR 5,00,000, or
• Both

  Summarizing the above provisions we, can conclude that the companies which maintain books of accounts at any place in India other than registered office shall comply with any of the following option:

• Change its registered office to the present place of business where books of accounts are actually maintained, or
• Keep its books of accounts and records at actual registered office only, or
• Report the other address in India where books of accounts are maintained by filing Form AOC-5.

Thus, books of accounts shall be at registered office to avoid penalty. __________________________________________________________________________________________