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MSME Samadhaan Filing Guide & Section 16 Interest Calculator (2026)

After day 45, the statute itself starts charging interest on your buyer’s bill.

A working guide to filing on the MSME Samadhaan portal in 2026 who qualifies, how Section 16 compound interest is actually computed, what the two governing Supreme Court rulings settled, and the step-by-step path from complaint to enforceable award.

Section 16 Interest Ledger

3 × RBI BANK RATE • MONTHLY RESTING
Confirm the current RBI Bank Rate.
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0%
0%
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Enter details and click Calculate.

Work out what's actually owed

Section 16 of the MSMED Act compounds interest monthly at three times the RBI Bank Rate automatically, from the day after the appointed day, with no notice required. Enter the figures below for an illustrative reading.

Six things to get right before you file

Who can actually file

The Samadhaan scheme protects micro and small enterprises engaged in manufacturing or services. A valid complaint needs three conditions to hold at once.

one-number-round

Udyam Registration predates the supply

It must have been active on the date of the transaction in dispute, not merely on the date of filing. This is the single most misunderstood condition, and getting it wrong is fatal to the claim.

two-number-round

The transaction fits the statutory definition

The supply of goods or services has to fall within "supplier" as defined under Section 2(n) of the MSMED Act.

three-number-round

Payment is genuinely overdue

The buyer must have missed the appointed day under Section 2(b) — the date fixed in writing, or the 45th day from acceptance, whichever comes first.

M/s Silpi Industries v. Kerala State Road Transport Corporation
 
(2021) 18 SCC 790 · decided 29 June 2021

The Supreme Court treated Udyam Registration as a substantive eligibility condition rather than paperwork: a supplier cannot reach back and claim MSMED protection for supplies made before they registered. Register before you start supplying — not after the payment dispute begins. The Court also confirmed that the ordinary three-year limitation period under Article 137 of the Limitation Act, 1963 applies, running from the date the cause of action arises. A complaint filed late carries a complete limitation defence for the buyer.

How the 45-day clock actually runs

The clock starts on the “day of acceptance” not the invoice date, unless the two happen to coincide. Suppliers who compute interest from the invoice date alone tend to land on the wrong figure.

Day 0
Goods or services delivered
Day 15
Window to raise a written objection closes
Day 16
Deemed acceptance if buyer stayed silent
Day 45
Appointed day — outer limit for payment
Day 46+
Section 16 interest accrues automatically

Any clause attempting to push payment beyond 45 days is void to that extent. Buyers cannot contract their way around Section 15.

Reading the worked example

Three times the Bank Rate, compounded monthly, regardless of anything the supply contract says to the contrary. Here’s how that plays out over a full year of non-payment, using an illustrative Bank Rate of 5.50% confirm the figure currently in force before relying on it.

Item Value
Principal overdue ₹10,00,000
Appointed day 1 Jan 2026
As-of date 31 Dec 2026
Statutory rate (3 × Bank Rate) 16.50% p.a.
Compounding Monthly rests
Effective annual rate ≈ 17.81% p.a.
Interest accrued over 12 months ≈ ₹1,78,100
Total recoverable ≈ ₹11,78,100

This is before any further compensation the Facilitation Council may separately award. If the Bank Rate changes mid-delay, split the ledger into segments at each effective date rather than applying one rate throughout.

Section 23 of the Act closes one more door for buyers: the interest paid under Section 16 cannot be claimed as a deductible business expense under the Income Tax Act, 1961.

Section 43B(h) the tax side of delay

The Finance Act, 2023 added clause (h) to Section 43B, effective from Assessment Year 2024-25. Any sum owed to a micro or small enterprise that stays unpaid past the Section 15 deadline is deductible only in the year it’s actually paid the unpaid amount gets added back to the buyer’s taxable income for the year it fell due. Medium enterprises and traders are outside this clause. The buyer’s tax auditor must report unpaid MSE dues under Clause 22 of Form 3CD.

Pays Within 45 Days
  • No Section 16 interest accrues.
  • Full deduction in the year the expense was incurred.
  • Nothing to report under Clause 22, Form 3CD.
Pays After 45 Days
  • Compound interest at 3 × Bank Rate, monthly rests, from day 46.
  • Deduction deferred to the year of actual payment; unpaid sum added back to taxable income meanwhile.
  • Auditor must disclose the unpaid dues in the Tax Audit Report.

What happens after you file

Samadhaan is a filing gateway. Once submitted, the complaint goes to the Facilitation Council in the supplier’s state not the buyer’s.

Step 1
Complaint forwarded to the State Micro and Small Enterprises Facilitation Council (MSEFC)
↓
Step 2 • Mandatory
Conciliation under Part III of the Arbitration and Conciliation Act, 1996 — conducted by the Council itself or an ADR institution it refers the matter to.
↓
If It Settles
Settlement carries the same status as an arbitral award on agreed terms — enforceable as such.
If It Fails
Council proceeds to arbitration under Section 18(3), treated as if the parties had a Section 7(1) arbitration agreement.
↓
Result
Final order is an arbitral award — enforceable as a civil court decree under Section 36, executable via Order 21 CPC.

Section 18(5) targets a 90-day resolution, though backlogs in some states mean real timelines can run longer. Where a Council sits dormant, a supplier can move the High Court under Article 226 to compel it to act.

Gujarat State Civil Supplies Corp. Ltd. v. Mahakali Foods Pvt. Ltd.
 
(2023) 6 SCC 401 · decided 31 October 2022 · Lalit, CJI & Trivedi, J.

A buyer cannot point to a contractual arbitration clause to escape the Facilitation Council’s jurisdiction. The Court held the MSMED Act, as a special statute, displaces the general Arbitration and Conciliation Act, 1996 a Section 18 reference stands regardless of what the supply contract’s dispute-resolution clause says. The Court also fixed the relevant moment for “supplier” status at contract formation, not at the date of filing.

The 75% pre-deposit rule

A buyer who wants to challenge an MSEFC award under Section 34 of the Arbitration and Conciliation Act first has to deposit 75% of the awarded sum principal plus Section 16 interest up to the award date. This is mandatory, not a matter of court discretion.

The rule exists to stop buyers from filing a Section 34 challenge purely to stall and keep holding the supplier’s money during years of litigation. Courts also retain discretion to release part of the deposit to the supplier while the challenge runs which means the precision of the Council’s interest computation directly sets the size of the barrier a buyer has to clear before even getting a hearing.

Filing on Samadhaan, step by step

one-number-round

Verify Udyam Registration status

Confirm it was active on the date of the disputed supply, then pull your URN, PAN, and the mobile number linked to your Udyam profile.

two-number-round

Assemble the evidence

Purchase order, tax invoices, delivery proof, acceptance correspondence, and bank statements showing the outstanding balance plus a ledger computing Section 16 interest from the appointed day, segment by segment if the Bank Rate changed.

three-number-round

Authenticate on the portal

Go to samadhaan.msme.gov.in, choose "Case Filing for Entrepreneur / MSE Units," and verify your URN with the OTP sent to your registered mobile number.

four-number-round

Enter the statutory particulars

Buyer's name, address, GSTIN, principal due, appointed day, and computed interest. Getting the appointed day wrong is the single most consequential error at this stage.

five-number-round

Upload supporting documents

Every invoice, purchase order, delivery record, and piece of correspondence dated, signed where required, and legible, within the portal's file-size limits.

six-number-round

Submit and keep the case number

The portal issues a case number and routes the complaint to the relevant state MSEFC. That number is needed for every hearing notice and follow-up from here on.

Where filings usually go wrong

Registration timing

If Udyam Registration post-dates a supply, Silpi Industries bars the claim for that supply specifically mixed pre- and post-registration supplies need to be separated out.

Wrong appointed day

The 45-day clock runs from acceptance or deemed acceptance, not the invoice date get this wrong and both the interest figure and the limitation analysis are wrong.

Thin documentation

A buyer who denies receipt is hard to rebut without a signed purchase order, a valid tax invoice, and delivery acknowledgement obtained at the time, not after the dispute starts.

Ignoring limitation

The three-year period under Article 137 runs from the date payment fell due. Wait past that and the claim is barred outright.

Unreserved partial payment

Accepting part-payment without writing "without prejudice to the remaining claim" can be read as waiving the balance and the interest on it.

Frequently Asked Questions

Who can file a complaint on the MSME Samadhaan portal?

Only micro and small enterprises with a valid Udyam Registration active on the supply date. Medium enterprises and traders sit outside Sections 15–24 of the MSMED Act regardless of their Udyam status.

Three times the RBI Bank Rate, compounded monthly. At an illustrative 5.50% Bank Rate, that’s 16.50% per annum compounded confirm the rate currently notified by the RBI before relying on any specific figure.

No. Gujarat State Civil Supplies Corp. v. Mahakali Foods (2022) held the MSMED Act overrides the Arbitration and Conciliation Act a Section 18 reference goes ahead regardless of what the supply contract’s arbitration clause says.
A buyer challenging an MSEFC award under Section 34 must first deposit 75% of the awarded amount. It’s mandatory, not discretionary, and exists specifically to deter challenges filed only to stall payment.
Only to micro and small enterprises. From AY 2024-25, sums unpaid past 45 days are deductible only on actual payment so a delaying buyer faces both 16.5% compound interest and a tax disallowance on the same amount.

For Enquiry

Adv. Suresh Kumar, Founding Advocate and Senior Partner, Aran Law Associates, Chennai - Property and Debt Recovery Lawyer

Adv.Suresh Kumar

Aran Law

About the Author

Founding Advocate and Senior Partner

Adv. Suresh Kumar is the Founder and Managing Attorney of Aran Law, with over 18 years of litigation and legal advisory experience. He is enrolled with the Bar Council of Tamil Nadu and Puducherry and practises before the Madras High Court, City Civil Court, DRT Chennai, NCLT Chennai Bench, and district courts across Tamil Nadu. He holds a BA, BL (Hons), an M.Sc in Criminology, and postgraduate qualifications in Victimology and Juvenile Justice.

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