The Registrar of Companies, Mumbai II, issued an adjudication order dated July 2, 2026 under Section 454 of the Companies Act, 2013 imposing a penalty under Section 450 for violation of Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014. The matter arose from a suo motu adjudication application filed on December 11, 2024 regarding incorrect filing of Form AOC-4 for FY 2023–24. The application stated that while filing Form AOC-4, the company inadvertently selected “No” instead of “Yes” in Field No. 12 relating to the applicability of consolidated financial statements. The form was digitally signed by the director, who, under Rule 8(3), was responsible for the correctness of the contents and attachments of the e-form. In reply to the show cause notice, the director admitted the default, accepted the proposed penalty, and undertook to comply with the order. The Adjudicating Officer imposed a penalty of ₹10,000 on the director. The noticee was directed to rectify the default and pay the penalty within 90 days, and an appeal may be filed before the Regional Director, Navi Mumbai, within 60 days.
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/07-2026/MR/02476 Dated: 02/07/2026
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 DHOOT HOLDINGS PRIVATE LIMITED [herein after known as Company] bearing CIN U27320MH2020PTC336825, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at PLOT NO. AL-18, AL-19, MIDC, SHENDRA SEZ AREA, NA AURANGABAD AURANGABAD MAHARASHTRA INDIA 431021
Individual details:
In the matter relating to RAHUL RADHAVALLABH DHOOT —————-
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 Registrar of Companies Mumbai-II (hereafter referred to as the ROC) is in receipt of a suo-moto Adjudication application vide SRN N23923519 dated December 11th 2024 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 AOC-4 with SRN N15715634 for Financial Year 2023-24.
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 at the time of filing Form AOC-4for the Financial Year 2023-2024, the applicant inadvertentely selected “No” instead of “Yes” in field no. 12 of the form for applicability of Consolidated financial statements. The said form was digitally signed by Mr. Rahul Radhavallabh Dhoot, 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. Rahul Radhavallabh Dhoot, is liable for penalty under section 450 of the Companies Act, 2013.
2. the noticee in his reply to show cause notice has accepted the penalty as proposed in the SCN and has undertaken to comply with the order passed by Registrar of Companies Mumbai-II, hence no e-hearing is scheduled and order is passed ex-parte.
E.Order:
1. i. The noticee in his reply to show cause notice has submitted that he admit the default referred to in the Notice, the inadvertent selection of “No” instead of “Yes” in field no. 12 of the form AOC-4 with SRN N15715634.
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. 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 Rahul Radhavallabh Dhoot, having DIN as 00273337.
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 | RAHULRAD HAVALLABHDHOOT having DIN as 00273337 |
|
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.
Anannya Saikia,
Registrar of Companies
ROC Mumbai II
