Under Section 2(20) of the Companies Act, 2013, which of the following is NOT included in the definition of 'company'? 

Section 2(20) defines 'company' as a company incorporated under this Act or under any previous company law. A partnership firm registered under the Indian Partnership Act, 1932 is a fundamentally different legal entity-it is governed by the Partnership Act and does not have a separate legal personality in the same sense as a company (though recent jurisprudence has evolved on this). Section 2(42) separately defines 'foreign company' as any company or body corporate incorporated outside India which has a place of business in India. The Companies Act creates a distinct legal framework for companies-bodies corporate with separate legal personality, limited liability of members, perpetual succession, and transferable shares-characteristics not shared by partnership firms.