The document is an adjudication order issued by the Registrar of Companies, Hyderabad under Section 454 of the Companies Act, 2013 for violation of Section 450 read with Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014. The company filed e-Form MGT-7A for the financial year 2024-25 on 27.12.2025 with incorrect shareholding details, as the attached shareholder statement omitted the transfer of 5,000 equity shares from Mrs. Ayushi Chandrashekar Meshram to Mr. Shankar Dulat Sukhadeve effected on 02.05.2024. A show cause notice was issued, the company submitted its reply, and no e-hearing was sought. The Adjudicating Officer held that filing an incorrect statutory e-form attracted liability under Rule 8(3) read with Section 450, and that seeking to mark the form as defective did not remove the completed contravention. As the company qualified as a small company under Section 2(85), the reduced penalty under Section 446B was applied. A penalty of ₹5,000 each was imposed on the company and its two officers in default. The order also directs rectification of the filing, payment of the penalty within 90 days, provides for an appeal before the Regional Director, Hyderabad within 60 days, and refers to Section 454(8) for non-payment consequences.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Hyderabad
2nd Floor Corporate Bhawan, GSI Post, Tattiannaram, Bandlaguda, Nagole, Hyderabad, Telangana, India, 500068
Phone: 040-29805427/29804327
E-mail: roc.hyderabad@mca.gov.in
Order ID: PO/ADJ/05-2026/HD/02128 | Dated: 17/06/2026
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.
B. Company details:
In the matter relating to STRATEGYGAINS INFOCOM PRIVATE LIMITED [herein after known as Company] bearing CIN U74999TG2022PTC161572, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at 12A02 A2, 13TH FLOOR, MANJEERA TRINITY KPHB/KUKATPALLY NA HYDERABAD RANGAREDDI TELANGANA INDIA 500072
Individual details:
In the matter relating to SHANKAR DULAT SUKHADEVE___________________________________________
In the matter relating to HIRA SHANKAR SUKHADEOE___________________________________________
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 – M/s. STRATEGYGAINS INFOCOM PRIVATE LIMITED has filed an Adjudication application dated 23.02.2026 for adjudication of default u/s 450 of the CA, 2013. As per the application, the Company filed its Statutory Returns for the Financial Year 2024-25, e-Form MGT-7A vide SRN: AC0600320 led on 27.12.2025 and while filing the said form, typo error occurred in shareholding pattern in the attachment details of Shareholder or Debenture holder? excel attached in the e-Form MGT-7A with old shareholding details. However, the company has passed the resolutions and transferred 5000 Equity Shares from Mrs. Ayushi Chandrashekar Meshram to Mr. Shankar Dulat Sukhadeve on 02.05.2024 and the same was not given effect in the attachments of e-Form MGT-7A for the financial year 2024-25.
2. The Noticees have not requested for e-hearing through the e-Adjudication Portal and the Adjudicating Officer is also of the view that no e-hearing is required in the present matter.
E.Order:
1. Whereas a Show Cause Notice bearing No. SCN/ADJ/04-2026/HD04131 dated 16.04.2026 was issued to the Company and its Officers in Default (hereinafter referred to as the “Notice(s)”) under Section 454 read with Section 450 of the Companies Act, 2013 on account of incorrect filing of e-Form MGT-7A vide SRN AC0600320 on 27.12.2025 for the Financial Year 2024-25.B. A reply to the aforesaid Show Cause Notice was received from the Notice(s) on the e-Adjudication Portal on 29.04.2026.C. The Notice(s) have not sought an e-hearing through the e-Adjudication Portal and the Adjudicating Officer is also of the opinion that no e-hearing is necessary in the facts and circumstances of the present case.D. Upon examination of the suo-moto application, documents available on record and submissions made by the Notice(s), it is observed that the Company filed e-Form MGT-7A vide SRN AC0600320 on 27.12.2025 for the Financial Year 2024-25. The attachment namely ?Details of Shareholder or Debenture Holder? filed along with the said e-Form did not reflect the transfer of 5,000 Equity Shares from Mrs. Ayushi Chandrashekar Meshram to Mr. Shankar Dulat Sukhadeve effected on 02.05.2024. As a result, the shareholding particulars contained in the attachment were incorrect and did not represent the actual shareholding position of the Company.E. The MCA electronic registry is a public record, and statutory filings are relied upon by regulators, creditors, shareholders, and other stakeholders. Filing an e-form with incorrect contents and/or enclosures defeats the purpose of an electronic registry and directly triggers the responsibility fixed under Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014.In the present case, the impugned e-form was filed with incorrect particulars/enclosures, which has been admitted by the Company. All the Directors are liable for contravention of Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014.The request to mark the form as defective is an administrative rectification step and does not erase the completed contravention arising from filing an incorrect statutory e-form. Penalty liability under Rule 8(3) read with Section 450 of the Companies Act 2013 therefore remains attracted.F. In exercise of the powers conferred under Section 454 of the Companies Act, 2013, the Company, and its Officers in default shall be liable to impose penalty for violation of Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 read with Section 450 of the Companies Act, 2013. The period of default is considered to be the date of filing Form MGT-7A i.e. 27.12.2025. Therefore, the Company and officers in default shall be liable to a penalty of Rs. 10,000/- (Ten Thousand Only) each.G. As per the e-Form MGT-7A filed on 27.12.2025, the paid-up capital of the Company is Rs.1,00,000/- and turnover was Rs. 4,05,91,000/-. Therefore, the Company is a Small Company as per provisions of Section 2(85) of the Act, the Company and its officers in default are liable for penalty under Section 450 subject to the provisions of Section 446B of the Companies Act 2013. As per the Section 446B, ?Notwithstanding anything contained in this Act, if penalty is payable for non-compliance of any of the provisions of this Act by a One Person Company, small company, start-up company or Producer Company, or by any of its officer in default, or any other person in respect of such company, then such company, its officer in default or any other person, as the case may be, shall be liable to a penalty which shall not be more than one-half of the penalty specified in such provisions subject to a maximum of two lakh rupees in case of a company and one lakh rupees in case of an officer who is in default or any other person, as the case may be.?H. Now, in exercise of the powers conferred on the Adjudicating Officer vide Notification dated 24th March 2015, a penalty of Rs. 5,000/- (Rupees Five Thousand only) each on the Company and it very Officer in default under Section 450 of the Companies Act, 2013 for default under Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014.I. The Company/Notice(s) are further directed to rectify the defect by taking necessary steps on the MCA portal (including filing the correct/appropriate e-form and making necessary request(s) for marking the incorrect filing as defective, wherever such facility/process is prescribed), within prescribed time from the date of receipt of this order, and to intimate this office with proof of compliance.J. It is clarified that this Order is confined to adjudication of the default arising from filing of the incorrect e-Form MGT-7A and shall not be construed as approval of any modification in the shareholding structure other than rectification of the filing error brought out in the present proceedings.
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 | STRATEGYGAIN S INFOCOM PRIVATE LIMITED having CIN as U74999TG2022P TC161572 | 5000 | 0 | 200000 | |
| 2 | SHANKAR DULAT SUKHADEVE having DIN as 07990010 |
5000 | 0 | 50000 | |
| 3 | HIRA SHANKAR SUKHADEOE having DIN as 09571376 | 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 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.
Satya Singh,
Registrar of Companies
ROC Hyderabad
