The Registrar of Companies, Cuttack, acting under Section 454 of the Companies Act, 2013, imposed penalties on Satguru Metals Limited and its directors for failing to file the Reconciliation of Share Capital Audit Report (Form PAS-6) for the half-year ended March 31, 2025, within the prescribed timeline under Rule 9A(8) of the Companies (Prospectus and Allotment of Securities) Rules, 2014. The company was required to file the form by May 31, 2025, but submitted it only on May 11, 2026. Although the company later rectified the default and cited financial constraints as the reason for the delay, the adjudicating officer held that subsequent filing does not erase the period of non-compliance. The authority concluded that the default continued from June 1, 2025, until May 10, 2026, attracting penalty under Section 450. Consequently, the company was fined ₹2 lakh, while each of the three defaulting directors was penalized ₹50,000, being the statutory maximum applicable.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Cuttack
ROC-cum-Official Liquidator, Ministry Of Corporate Affairs, Corporate Bhawan, 2nd & 3rd Floor, Plot No-9(P), Sector-1, CDA, Cuttack, Orissa, India, 753014
Phone: 0671-2366952
E-mail: roc.cuttack@mca.gov.in
Order ID: PO/ADJ/06-2026/CT/02310 | Dated: 12/06/2026
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.
C. Company details:
In the matter relating to SATGURU METALS LIMITED [herein after known as Company] bearing CIN U271020R2007PLC009524, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at OPP. CRAZY COOL, MAIN ROAD DAILY MARKET NA ROURKELA ORISSA INDIA 769001
Individual details:
In the matter relating to KRIPAL SINGH DANG…………
In the matter relating to INDERPAL SINGH CHHABRA …………
In the matter relating to UJJWAL SINGH…………..
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 l[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 – It is observed that the Company was required to file ‘Reconciliation of Share Capital Audit Report’ in e-form PAS-6 pursuant to sub-rule 8 of Rule 9A of Companies (Prospectus and Allotment of Securities) Rules, 2014 to report the details and changes in the share capital of the Company on a half-yearly basis for the half year ended on 31/03/2025 with this office. However, as per the records available with this office, the company has failed to file the form PAS-6 for the said period till date. Therefore, the company has violated the provisions of Sub-rule 8 of Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules, 2014 and accordingly, the company and its every officers for the relevant period are liable for punishment under the provisions of Section 450 of the Companies Act, 2013.
2. The Company and its directors/officers in default have not responded to the show cause notices issued to them despite service through email as well as speed post. Therefore, to ensure an opportunity being heard, e-hearing was provided.
E. Order:
1.
(i) Shri Rahul Agrawal, CS, appeared in the e-hearing held on 07.05.2026, claiming to be the authorised representative of the company, however, no authorisation was submitted. He requested one weeks time to file the reply. The request was accepted and the next date of hearing was fixed for 13.05.2026. However, no one appeared in the e-hearing held on 13.05.2026 on behalf of the Company and its directors/officers in default, despite providing them reasonable opportunities of being heard.
(ii) However, the company vide e-mail dated 09.06.2026 has submitted a letter wherein the company has stated that :The company was required to file Form PAS-6 for the period FY 2018-19 (Quarter 2) to FY 2025-26. However, due to certain financial constraints faced by the company, the company was unable to complete the necessary compliance process and file the said form with the prescribed time limit.
The company acknowledges the requirement of compliance under the applicable provisions of the Companies Act, 2013 and rules made thereunder. The company has now taken necessary steps to ensure completion of the pending compliance and has filed all the necessary forms.
(iii) It is observed from the MCA portal that the company has filed the requisite e-form PAS-6 for the half-year ended on 31.03.2025 vide SRN-AC3417606 dated 11.05.2026.
(iv) As per requirement of Rule 9A(8) of the Companies (Prospectus and Allotment of Securities) Rules, 2014, the PAS-6 required to be filed within sixty days from the conclusion of each half year. Accordingly, the form PAS-6 for the half year ended 31.03.2025 was to be filed by the company on or before 31.05.2025. However, the company has filed the Form PAS-6 for the said half year ended 31.03.2025, only on 11.05.2026. The company has also acknowledged and admitted that the company was unable to file the said form within the prescribed time limit. Therefore, belated filing if any, can make good the offence, but the default continues from the due date of filing till the filing of the said form.
Having considered the facts and circumstances of the case and the documentary evidence available on record, it is concluded that the company and its directors/officers for the relevant period have violated the provisions of Rule 9A(8) of the Companies (Prospectus and Allotment of Securities) Rules, 2014. Therefore, I am imposing penalty upon the company and its Directors/Officers in default for the period from 01.06.2025 (due date of filing) to 10.05.2026 (last date up to which form was not filed) under the provisions of Section 450 of the Companies Act 2013.
(v) The company and the directors/officers in default shall pay the penalty amount as mentioned herein below through online mode in compliance with Rule 3(14) of the Companies (Adjudication of Penalties) Amendment Rules, 2019, within a period of 90 days from the date of receipt of this order, specifying the details of this order and the name of the noticee making such payment. Further, the company shall file e-Form INC-28 along with a copy of this order and the payment challans immediately after payment of the penalty amount.
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 | SATGURU METALS LIMITED having CIN as U271020R2007P LC009524 | 200000 | 0 | 200000 | |
| 2 | KRIPAL SINGH DANG having DIN as 01623170 | 50000 | 0 | 50000 | |
| 3 | INDERPAL
SINGH CHHABRA having DIN as 03147440 |
50000 | 0 | 50000 | |
| 4 | UJJWAL SINGH having DIN as
08968179 |
50000 | 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 Hyderabad 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.
Sitaram Gupta,
Registrar of Companies
ROC Cuttack
