The Registrar of Companies, Mumbai II, issued an order dated 29.06.2026 under Section 454 of the Companies Act, 2013 for adjudication of penalty relating to a violation of Section 450 by SURI CONSUMER PRIVATE LIMITED. The matter arose from a suo motu adjudication application filed vide SRN AC3893329 dated 12.06.2026 regarding incorrect filing of e-Form AOC-4 for FY 2024-25, in which the company inadvertently selected “Ind AS Taxonomy” instead of “AS Taxonomy” at Point No. 6. The form was digitally signed by Director Pranavi Suri. Referring to Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014, the order states that the authorised signatory and the certifying professional are responsible for the correctness of the contents and enclosures of the e-form. The person in default requested that the matter be decided without a personal hearing, and an ex parte order was passed. After considering the explanation that the error was inadvertent, clerical, unintentional and non-repetitive, the Adjudicating Officer imposed a penalty of ₹10,000 on Pranavi Suri under Section 450, directed rectification and payment within 90 days, and specified the appeal procedure under Section 454.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Mumbai II
100, Everest, Marine Drive, Mumbai, Maharashtra, India, 400002
Phone: 022-22812627
E-mail: roc.navimumbai@mca.gov.in
Order ID: PO/ADJ/06-2026/MR/02443 | Dated: 29/06/2026
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 SURI CONSUMER PRIVATE LIMITED [herein after known as Company] bearing CIN U74110MH2020PTC405020, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at CABIN NO 1, 3RD FLOOR PLOT NO. C109 & 110 TTC MIDC INDUSTRIAL AREA,PAWNE VILLAGE THANE THANE THANE MAHARASHTRA INDIA 400705
Individual details:
In the matter relating to PRANAVI SURI
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 – Whereas Registrar of Companies Mumbai-I I (hereafter referred to as the ROC) is in receipt of a suo-moto Adjudication application vide SRN AC3893329 dated 12.06.2026 filed by the Company (hereafter referred to as the Applicant) under Section 454 of the Companies Act, 2013 (hereinafter referred to as the Act) for default under Rule 8(3) of the Companies (the Registration Offices and Fees) Rules,2014 on account of incorrect filing of E-form AOC-4 for Financial Year 2024-25.
Rule 8 (1) of the Companies (The Registration Offices and Fees) Rules, 2014 reads as:
(1) An electronic form shall be authenticated by authorised signatories using digital signature and
(2) Rule 8 (3) reads as 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.
The applicant in adjudication application has stated that it had filed form AOC-4 for F.Y. 2024-25 vide SRN AC0523964 dated 27.12.2025. The applicant has further stated that while filing Form AOC-4 an inadvertent clerical error occurred in Point no. 6 relating to the selection of the applicable taxonomy. The radio button corresponding to “Ind AS Taxonomy” was selected instead of “AS Taxonomy”. The said form was digitally signed by Mr. Pranavi Suri, Director of the Company. As per Rule 8(3) of the Companies (The Registration Offices and Fees) Rules, 2014, the authorised signatory and the professional who certifies the form shall be responsible for correctness of contents of e-form and correctness of enclosures attached with the e-form. Thus, Mr. Pranavi surf, is liable for penalty under section 450 of the Companies Act, 2013.
2. The Person in default has submitted that no personal hearing is required in the matter and respectfully requests that the proceedings may kindly be decided on the basis of the documents and written submissions available on record. Therefore, no e-hearing was provided and order is passed ex-parte.
E. Order:
1. i. The person in default in her reply to show cause notice has submitted that while filing Form AOC-4 vide SRN AC0523964 dated 27.12.2025, an inadvertent clerical error persisted in Point No. 6 relating to the selection of the applicable taxonomy. The radio button corresponding to “Ind AS Taxonomy” continued to remain selected instead of “AS Taxonomy”.
ii. Rule 8 (3) of Companies (registration offices and fee) rules, 2014, reads as 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.
iii. The person in default in her reply to show cause notice further submitted that the default was neither intentional nor repetitive in nature but arose due to the continuation of the earlier erroneous selection. The Applicant assures the Hon’ble Authority that utmost care shall be exercised in future to avoid recurrence of such inadvertent errors.
iv. In view of the above facts and reply submitted by the person in default, a penalty of Rupees Ten Thousand (Rs.10000/-) is being imposed on Pranavi Suri, having DIN as 10771153.
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 | PRANAVI SURI having DIN as 10771153 |
|
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 Navi 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.
null,
Registrar of Companies
ROC Mumbai II
