The Registrar of Companies, Patna, issued an adjudication order dated 22 July 2026 under Section 454 of the Companies Act, 2013, for violation of Section 203(5) by TECH SIS LIMITED for non-appointment of a Chief Financial Officer (CFO). The order states that the company, having a paid-up share capital of ₹14.80 crore as on 29.03.2021, did not appoint a CFO, resulting in non-compliance from 28.09.2021 to 27.03.2025. During the hearing held on 07.07.2026, the company’s authorised representative submitted that the default arose due to financial hardships, inability to identify a suitable candidate, and that Mr. Akalesh Singh was appointed CFO with effect from 28.03.2025. The Adjudicating Officer found the submissions unsatisfactory and imposed a penalty of ₹5,00,000 on the company, ₹3,69,000 on Sachin Goswami, and ₹5,00,000 each on Tapash Chaudhuri, Dhiraj Singh, Rituraj Kishore Sinha, Ravindra Kishore Sinha, Rita Kishore Sinha, Brajesh Kumar and Shankar Subramanian. The order directs rectification of the default and payment of penalties within 90 days, provides for appeal to the Regional Director, Kolkata within 60 days, and refers to Section 454(8) for consequences of non-payment.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Patna
ROC-cum-Official Liquidator, Ministry Of Corporate Affairs, High Court Of Patna, Maurya Lok Complex, Block “A” 4th Floor, Dak Bungalow Road, Patna, Bihar, India, 800001
Phone: 0612-2950121
E-mail: roc.patna@mca.gov.in
Order ID: PO/ADJ/07-2026/PT/02531 | Dated: 22/07/2026
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 203(5) 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 TECH SIS LIMITED [herein after known as Company] bearing CIN U75300BR2010PLC015484, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at ANNAPURNA BHAWAN, TELEPHONE EXCHANGE ROAD KURJI NA PATNA BIHAR INDIA 800010
Individual details:
In the matter relating to SACHIN GOSWAMI —————-
In the matter relating to TAPASH CHAUDHURI —————-
In the matter relating to DHIRAJ SINGH —————-
In the matter relating to RITURAJ KISHORE SINHA —————-
In the matter relating to RAVINDRA KISHORE SINHA —————-
In the matter relating to RITA KISHORE SINHA —————-
In the matter relating to BRAJESH KUMAR —————-
In the matter relating to SHANKAR SUBRAMANIAN —————-
C. Provisions of the Act:
If any company makes any default in complying with the provisions of this section, such company shall be liable to a penalty of five lakh rupees and every director and key managerial personnel of the company who is in default shall be liable to a penalty of fifty thousand rupees and where the default is a continuing one, with a further penalty of one thousand rupees for each day after the first during which such default continues but not exceeding five lakh rupees.
D. Facts about the case:
1. Default committed by the officers in default/noticee – On 29.03.2021 company has paid up share capital 14,80,00,000/-and company has not appointed CFO. Hence, company has non-compliance of Section 203 of the Companies Act, 2013.
2. The hearing was scheduled on 07.07.2026 so that the company and its directors/officers-in-default could make an oral representation before the undersigned adjudicating officer in respect of show cause notice issued on 07.04.2026. On the date of hearing, CS Suryakant Kumar, Practicing Company Secretary (Membership No. 27610, COP No. 10207) has attended the hearing who was duly authorised to execute the same. He has made his submissions inter alia stating as ? that as on 29.03.2021, the paid-up capital of the company stood at Rs. 14,80,00,000/- and accordingly, the provisions relating to appointment of Key Managerial Personnel, including Chief Financial Officer (CFO), under section 203(4) of the Act, such vacancy was required to be filled by the Board within a period of six months, i.e., by September 28, 2021. That the company has been continuously incurring losses and facing severe financial hardships during the relevant period. The default occurred solely due to genuine financial difficulties and practical constraints faced by the company. That despite sincere efforts, the company was unable to identify and appoint a suitable candidate for the position during this period. Eventually, the company appointed Mr. Akalesh Singh as Chief Financial Officer with effect from March 28, 2025. That during the relevant period, the overall management and administration of the company was vested in and controlled by Mr. Tapash Chaudhuri (DIN: 00054233). …
E. Order:
1. The submissions made found to be unsatisfactory. Accordingly, penalty is imposed for the non-compliance made by the company u/s. 203 of the Companies Act, 2013, i.e., non-appointment of Chief Financial Officer for the period between 28.09.2021 to 27.03.2025 on the company and its directors and key managerial personnel of the company.
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 | TECH SIS LIMITED having CIN as U75300BR2010P LC015484 | 500000 | 0 | 500000 | |
| 2 | SACHIN GOSWAMI having PAN as ALMPG4682P | 369000 | 0 | 500000 | |
| 3 | TAPASH CHAUDHURI having DIN as 00054233 | 500000 | 0 | 500000 | |
| 4 | DHIRAJ SINGH having DIN as
00066899 |
500000 | 0 | 500000 | |
| 5 | RITURAJ KISHORE SINHA having DIN as 00477256 | 500000 | 0 | 500000 | |
| 6 | RAVINDRA KISHORE SINHA having DIN as 00945635 | 500000 | 0 | 500000 | |
| 7 | RITA KISHORE SINHA having DIN as 00945652 | 500000 | 0 | 500000 | |
| 8 | BRAJESH KUMAR having DIN as 07833562 | 500000 | 0 | 500000 | |
| 9 | SHANKAR SUBRAMANIAN having DIN as 08021571 | 500000 | 0 | 500000 |
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 Kolkata 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.
Dr Rameshkumar,
Registrar of Companies
ROC Patna
