The Registrar of Companies, Mumbai-I imposed a penalty under Section 450 of the Companies Act, 2013 on a director for filing incorrect details in Form AOC-4 for FY 2024-25. The company had filed the form on 27.01.2026, but due to an inadvertent clerical or technical error, the date of the Annual General Meeting and its due date were wrongly mentioned as 01.04.2025 and 31.03.2025 respectively. Since the e-form was digitally signed and certified by the director, the ROC held him responsible under Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 for ensuring correctness of the contents and attachments in the electronic filing. The adjudicating authority observed that incorrect certification of the form constituted a contravention attracting penalty under Section 450. Considering the applicability of Section 2(85), the penalty was reduced from Rs. 10,000 to Rs. 5,000. The ROC also directed rectification of the filing through a fresh Form AOC-4 without altering the approved 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/05-2026/MH/02121 Dated: 13/05/2026
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, 2014 for adjudging penalties under the provisions of this Act.
B. Company details:
In the matter relating to STATUS AIR VISION PVT LTD [herein after known as Company] bearing CIN U63030MH1987PTC043839, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at 99 RATNAJYOT INDUSTRIAL ESTATE IRLA LANE VILE PARLE (WEST) NA MUMBAI MAHARASHTRA INDIA 400056
Individual details:
In the matter relating to SATYEN HIMMAT BHATIA ——
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 -I (hereinafter referred to as the ROC, Mumbai I) is in receipt of a suo-motu Adjudication Application on 23.03.2026 filed by Mr. Satyen Himmat Bhatia, Director (DIN: 02317289) (hereinafter referred to as the Applicant) under Section 454 of the Companies Act, 2013 (hereinafter referred to as the Act) on account of incorrect filing of E-form AOC-4 for Financial Year 2024-25 (hereinafter referred to as FY 2024-25).
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 applicants stated that the Company had filed form AOC-4 for the F.Y. 2024-25 vide SRN AC1710236 on 27.01.2026. The Applicant stated that due to inadvertent clerical or technical error, the date of Annual General Meeting and due date of Annual General Meeting was wrongly mentioned as 01.04.2025 and 31.03.2025 respectively. The said form was digitally signed, and declaration made by Mr. Satyen Himmat Bhatia, Director (DIN: 02317289).
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. Satyen Himmat Bhatia, Director (DIN: 02317289) is liable to penalty subject to the provisions Section 450 of the Companies Act, 2013.
2. Noticee did not request for E-hearing and the Adjudicating officer is also of the view that no E-hearing is required in the instant case.
E. Order:
1. A. Show Cause notice bearing ID: SCN/ADJ/04-2026/MH/04179 dated 16.04.2026 was issued to the Officer in default viz. Mr. Satyen Himmat Bhatia, Director (DIN: 02317289) (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 filing incorrect details in E-form AOC-4 for FY 2024-25.
B. No reply from the noticee received on E-Adjudication portal within due date. However, noticee vide email dated 06.05.2026 informed that due to some emergency he was forced to go out of station and unable to reply to show cause notice. He further informed that he does not want to go for E-hearing. The Adjudicating officer is also of the view that no E-hearing is required in the instant case.
C. On perusal of the Application and considering the facts, it is observed that the Company filed E-Form AOC-4 vide SRN AC1710236 on 27.01.2026. While filing the form at page 3 the Company the date of Annual General Meeting and due date of Annual General Meeting was wrongly mentioned as 01.04.2025 and 31.03.2025 respectively. 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.
D. 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.
E. Further, the aforementioned E-form AOC-4 was digitally signed, and Declaration was given by Mr. Satyen Himmat Bhatia, Director (DIN: 02317289). 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.
F. The period of default is considered to be the date of filing Form AOC-4 that is 27.01.2026. Therefore, the officer in default namely Mr. Satyen Himmat Bhatia, Director (DIN: 02317289) shall be liable to a penalty of Rs. 10,000/- (Rupees Ten Thousand Only). However, the provisions of Section 2(85) of the Act are applicable in the instant case. Thus, the officer in default namely Mr. Satyen Himmat Bhatia, Director (DIN: 02317289) shall be liable to a penalty of Rs. 5,000/- (Rupees Five Thousand Only).
G. Now, in exercise of the powers conferred on the Adjudicating Officer vide Notification dated 24th March 2015, I hereby impose a penalty of Rs. 5,000/- (Rupees Five Thousand only) on Mr. Satyen Himmat Bhatia, Director (DIN: 02317289) under Section 450 read with Section 2(85) of the Act for default under Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014.
H. 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 AC1710236 on 27.01.2026.
I. 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 on whom penalty imposed (B) | Rectification of Default required (C) | Penalty Amount (D) | Additional Penalty
(E) (*Per day of continuing default i.e. date of rectification of default less order issue date) |
Maximum limit for Penalty (F) |
| 1 | SATYEN HIMMAT BHATIA having DIN as 02317289 | Rectify the mistakes pointed out in the order and file a fresh Form AOC-4. | 5000 | 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].
6. For 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
