The Registrar of Companies, Mumbai initiated adjudication proceedings under Section 454 of the Companies Act, 2013 against the company’s Managing Director for filing incorrect details in E-form AOC-4 for FY 2021–22. The company failed to attach consolidated financial statements despite having a subsidiary and incorrectly marked that such statements were not required. As per Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014, the authorized signatory is responsible for the accuracy of e-forms and attachments. The form, signed and certified by the Managing Director, was processed under the Straight Through Process (STP), but later found to be erroneous. After considering the reply and hearing, the Adjudicating Officer held the signatory liable for the default under Section 450. A penalty of ₹10,000 was imposed, with directions to rectify the error without altering approved financial statements. The order clarified that it is limited to rectification and does not affect the validity of financial statements.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Mumbai I
100, Everest, Marine Drive, Mumbai, Maharashtra, India, 400002
Phone: 022-22812627
E-mail: roc.mumbai@mca.gov.in
Order ID: PO/ADJ/04-2026/MH/02059 | Dated: 24/04/2026
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 450 OF THE COMPANIES ACT, 2013.
A. Appointment of Adjudicating Officer:
Ministry of Corporate Affairs vide its Gazette notification number S.O. 698(E) dated 10/02/2026 appointed undersigned as Adjudicating Officer in exercise of the powers conferred by section 454 of the Companies Act, 2013 [herein after known as Act] read with Companies (Adjudication of Penalties) Rules, 2014for adjudging penalties under the provisions of this Act.
B. Company details:
In the matter relating to LORVEN INTERNATIONAL LIMITED [herein after known as Company] bearing CIN U74999MH2006PLC165838, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at LORVEN HOUSE, OPP. KAKA PETROL PUMP, NEAR METRO MALL, LBS MARG, BHANDUP (WEST ), NA MUMBAI MAHARASHTRA INDIA 400078
Individual details:
In the matter relating to PANKAJ BALDEVKUMAR AGGARWAL ________________________________
C. Provisions of the Act:
If a company or any officer of a company or any other person contravenes any of the provisions of this Act or the rules made thereunder, or any condition, limitation or restriction subject to which any approval, sanction, consent, confirmation, recognition, direction or exemption in relation to any matter has been accorded, given or granted, and for which no penalty or punishment is provided elsewhere in this Act, the company and every officer of the company who is in default or such other person shall be 1[liable to a penalty of ten thousand rupees, and in case of continuing contravention, with a further penalty of one thousand rupees for each day after the first during which the contravention continues, subject to a maximum of two lakh rupees in case of a company and fifty thousand rupees in case of an officer who is in default or any other person]
D. Facts about the case:
1. Default committed by the officers in default/noticee – Whereas the Registrar of Companies, Mumbai (hereinafter referred to as the ROC) is in receipt of a suo-motu Adjudication Application on 11.02.2026. The instant Adjudication Application filed by Mr. Pankaj Baldevkumar Aggarwal, Chairman and managing Director (DIN: 00744569) (hereinafter referred to as the Applicant) under Section 454 of the Companies Act, 2013 (hereinafter referred to as the Act) on account of filing of incorrect details in E-form AOC-4 filed vide SRN F56934193 for FY 2021-22.
Whereas Rule 8(1) and (3) of the Companies (The Registration Office and Fees) Rules, 2014 are reads as follows:
(1) An electronic form shall be authenticated by authorised signatories using digital signature.
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(3) The authorised signatory and the professional, if any, who certify e-form shall be responsible for the correctness of the contents of e-form and correctness of the enclosures attached with the electronic form.
Whereas the applicant stated that it had filed E-form AOC-4 vide SRN F56934193 on 12.01.2023. While filing the said form the Company inadverently failed to attach Consolidated financial statements with the E-form. Further, on perusal of the said form, it is observed that the Company has subsidiary Company. However, at point 12 of the said form that whether the consolidated financial statemets requried or not, the Company wrongly selected No. The said form was digitally signed and Declaration was given by Mr. Pankaj Baldevkumar Aggarwal, Chairman and managing Director (DIN: 00744569).
Whereas the authorized signatory, who certifies e-form shall be responsible for the correctness of the contents of e-form and correctness of the enclosures attached with the electronic form as required under the proviso of Rule 8(3) of Companies (The Registration Office and Fees) Rules, 2014. Thus, Mr. Pankaj Baldevkumar Aggarwal, Chairman and managing Director (DIN: 00744569) is liable to penalty subject to the provisions Section 450 of the Companies Act, 2013.
2. The Noticee requested for an E- hearing. Acceding to the request, an opportunity of being heard was granted to him by the Adjudicating Officer under the provisions of Section 454(4) of the Act on 22.04.2026.
E.Order:
1. A.Show Cause notice bearing ID: SCN/ADJ/03-2026/MH/04042 dated 24.03.2026 was issued to the Officer in default viz. Mr. Pankaj Baldevkumar Aggarwal, Chairman and managing Director (DIN: 00744569) (hereinafter referred to as the Noticee) under Section 454 read with Section 450 of the Act for default under Rule 8(1) and Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 of the Act on account of incorrect filing of E-form AOC-4 XBRL for FY 2021-22.
B.A reply of the noticee to the said Show Cause Notice was received on the E-adjudication portal on 24.03.2026.
C.The Noticee requested for an E- hearing. Acceding to the request, an opportunity of being heard was granted to him by the Adjudicating Officer under the provisions of Section 454(4) of the Act on 22.04.2026 at 03:11 PM (IST). In this regard, a notice bearing ID: EH/ADJ/04-2026/MH/01471 dated 17.04.2026 was issued.
D.The E-hearing was attended by Advocate R. T. RajGuroo on behalf of the noticee and he reiterated the written reply. E.On perusal of the Application and considering the facts, it is observed that the Company filed E-Form AOC-4 vide SRN F56934193 on 12.01.2023. While filing at point 12 of the said form that whether the consolidated financial statements required or not, the Company wrongly selected No. The said form got auto approved under Straight through Process (STP) mode. Certification of E-form which was in AOC-4 resulted in contravention of Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 of the Act.
F.The Rule 8(1) and Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 of the Act reads as under: 1.An electronic form shall be authenticated by authorised signatories using digital signature.
3.The authorized signatory and the professional, if any, who certify e-form shall be responsible for the correctness of the contents of e-form and correctness of the enclosures attached with the electronic form.
G.Further, the aforementioned E-form AOC-4 was digitally signed, and Declaration was given by Mr. Pankaj Baldevkumar Aggarwal, Chairman and managing Director (DIN: 00744569). Thus, he is liable for a penalty under Section 450 of the Act for default under Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 of the Act.
H. The period of default is considered to be the date of filing Form AOC-4 that is 12.01.2023. Therefore, the officer in default namely Mr. Pankaj Baldevkumar Aggarwal, Chairman and managing Director (DIN: 00744569) shall be liable to a penalty of Rs. 10,000/- (Rupees Ten Thousand Only). The Company does not fall under proviso of Section 2(85) of the Act.
I. Now, in exercise of the powers conferred on the Adjudicating Officer vide Notification dated 24th March 2015, I hereby impose a penalty of Rs. 10,000/- (Rupees Ten Thousand only) on Mr. Pankaj Baldevkumar Aggarwal, Chairman and managing Director (DIN: 00744569) under Section 450 of the Act for default under Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014.
J. It is hereby clarified that while filing new Form AOC-4, the Company shall not cause any change in financial statement and enclosures thereof as adopted by the Shareholders in General meeting which was filed in E-Form AOC-4 vide SRN F56934193 on 12.01.2023.
K. Further, it is also clarified that order is limited to rectifying the mistake in E-form AOC-4 and it shall have no consequence except rectification of E-form AOC-4.
2. The details of penalty imposed on the company, officers in default and others are shown in the table below:
| (A) | Name of person | Rectification of | Penalty Amount | Additional Penalty | Maximum limit for |
| on whom penalty imposed (B) | Default required
(C) |
(D) | (E) (*Per day of continuing default i.e. date of rectification of default less order issue date) | Penalty (F) | |
| 1 | PANKAJ BALDEVKUMAR AGGARWAL having DIN as 00744569 |
NA | 10000 | 0 | 50000 |
3. The notified officers in default/noticee shall rectify the default mentioned above and pay the penalty, so applicable within 90 days of receipt of the order.
4. The notified officers in default/noticee shall pay the penalty amount via ‘e-Adjudication’ facility which can be accessed through the respective login IDs on the website of Ministry of Corporate Affairs and upload the copy of paid challan / SRN of e-filing (if applicable) on the ‘e-Adjudication’ portal itself. It is also directed that the penalty so imposed upon the officers in default shall be paid from their personal sources/income.
5. Appeal against this order may be filed in writing with the Regional Director, RD Mumbai within a period of sixty days from the date of receipt of this order, in Form ADJ setting for the grounds of appeal and shall be accompanied by a certified copy of this order [Section 454 (5) & 454 (6) of the Act, read with Companies (Adjudication of Penalties) Rules, 2014].
For 6. penal consequences of non-payment of penalty within the prescribed time limit, please refer Section 454(8) of the Companies Act, 2013.
Chandan Kumar,
Registrar of Companies
ROC Mumbai I
