The case deals with failure to maintain statutory disclosure records under Section 184. The authority imposed penalties on all directors, emphasizing strict compliance and record-keeping obligations.
The ROC held that delayed filing of Form MGT-14 constitutes a clear violation of Section 117. Even if eventually filed, non-compliance within the prescribed timeline attracts monetary penalties on both company and officers.
The case addresses delayed filing of return of allotment beyond the mandated 15 days under Section 42(8). The authority imposed penalties, reinforcing strict compliance requirements for private placements.
The Tribunal held that member-based receipts may be exempt under the principle of mutuality. The matter was remanded to verify whether contributors and beneficiaries are identical.