The Registrar of Companies, Kolkata I, passed an adjudication order dated 27.07.2026 under Section 454 of the Companies Act, 2013 against Shogun Vinimay Private Limited for violation of Rule 12(1B) of the Companies (Accounts) Rules, 2014 read with Section 450 of the Companies Act, 2013. The Ministry of Corporate Affairs had appointed the Adjudicating Officer through Gazette Notification S.O. 698(E) dated 10.02.2026. On examination of MCA21 records, it was found that the company met the thresholds under Section 135(1) for FY 2021-22 but failed to file Form CSR-2 for that financial year within the prescribed timeline. A show cause notice dated 24.07.2026 was issued, and the company and its directors accepted the default as an erroneous omission, requested a lenient view, and stated that the default had been rectified. Exercising powers under Section 454, the Adjudicating Officer imposed penalties of ₹2,00,000 on the company and ₹50,000 each on Umang Dhanuka, Shanti Lal Bothra, and Mayank Dhanuka. The order directs payment within 90 days through the MCA e-Adjudication facility, provides for an appeal to the Regional Director, Kolkata in Form ADJ within 60 days, and refers to Section 454(8) for consequences of non-payment.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Kolkata I
4th Floor Plot No.IIIF/16, in AA-IIIF Rajarhat, New Town, Akandakeshari, Kolkata, West Bengal, India, 700135
Phone: 033-22877390
E-mail: roc.kolkata@mca.gov.in
Order ID: PO/ADJ/07-2026/WB/02584 Dated: 27/07/2026
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 SHOGUN VINIMAY PRIVATE LIMITED [herein after known as Company] bearing CIN U51109WB2005PTC106010, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at 113, PARK STREET, 7TH FLOOR, PODDAR POINT, NA KOLKATA WEST BENGAL INDIA 700016
Individual details:
In the matter relating to UMANG DHANUKA ——–
In the matter relating to SHANTI LAL BOTHRA —————
In the matter relating to MAYANK DHANUKA —————
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 – Upon examination of the electronic records maintained in the MCA21 portal, it is observed that the Company met the thresholds specified under Section 135(1) for the Financial Year 2021-22. However, the Company has failed to file Form CSR-2 for the said financial year (2021-22) within the prescribed statutory timeline.
As Rule 12(1B) of Companies (Accounts) Rules, 2014 states that: In terms of Rule 12(1B) of the Companies (Accounts) Rules, 2014, Every company covered under the provisions of sub-section (1) to section 135 shall furnish a report on Corporate Social Responsibility in Form CSR-2 to the Registrar for the preceding financial year (2021-22) and onwards as an addendum to Form AOC-4 or AOC-4 XBRL or AOC-4 NBFC (Ind AS), as the case may be:]
As per Section 450 of the Companies Act, 2013:- Under Section 450, 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].
2. E-Hearing not Requested
E. Order:
1. As per Ministry’s instruction regarding CSR Non-compliance it is observed that the Company met the thresholds specified under Section 135(1) for the Financial Year 2021-22. However, the Company has failed to file Form CSR-2 for the said financial year (2021-22) within the prescribed statutory timeline.
Show Cause notice vide SCN/ADJ/07-2026/WB/05251 dated 24/07/2026 was issued to the Company and its Directors. Reply has been received from the Company and all the Directors wherein the default has been accepted on account of erroneous omission and has requested lenient view of the same. Further as per replies received the company has made the default good.
As Rule 12(1B) of Companies (Accounts )Rules, 2014 states that : In terms of Rule 12(1B) of the Companies (Accounts) Rules, 2014, Every company covered under the provisions of sub-section (1) to section 135 shall furnish a report on Corporate Social Responsibility in Form CSR-2 to the Registrar for the preceding financial year (2020-2021) and onwards as an addendum to Form AOC-4 or AOC-4 XBRL or AOC-4 NBFC (Ind AS), as the case may be.
As per Section 450 of the Companies Act, 2013:- Under Section 450, 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].
In exercise of the powers conferred under Section 454 of the Companies Act, 2013, the undersigned hereby imposes penalty for violation of Rule 12(1B) of Companies (Accounts )Rules, 2014 read with Section 450 of the Companies Act, 2013, as under:
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 | SHOGUN VINIMAY PRIVATE LIMITED having CIN as U51109WB2005P TC106010 | 200000 | 0 | 200000 | |
| 2 | UMANG DHANUKA having DIN as 00201655 | 50000 | 0 | 50000 | |
| 3 | SHANTI LAL BOTHRA having DIN as 00662857 | 50000 | 0 | 50000 | |
| 4 | MAYANK DHANUKA having DIN as 00747034 | 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 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.
null,
Registrar of Companies
ROC Kolkata I
