The Registrar of Companies (ROC) in Goa has imposed a penalty on Auraelite Tech Private Limited and its directors for a violation of the Companies Act, 2013. The penalty order, dated September 19, 2025, addresses the company’s failure to maintain a registered office as required by Section 12 of the Act. The issue came to light after a complaint was received, prompting the ROC to send a letter to the company’s registered address, which was returned with the postal remark, “Addressee Left.”
Following the undelivered letter, the ROC issued a show cause notice to the company and its directors, Ashish Kesavat and Sandeep Keshawat. However, neither the company nor the directors submitted a response by the deadline. As a result of this non-compliance, the Adjudicating Officer has levied a penalty of ₹50,000 on the company and an additional ₹50,000 each on both directors. Since the company is classified as a “Small Company,” the penalty was reduced under Section 446B of the Act. The company has been directed to rectify the default by establishing a functional registered office and to pay the total penalty amount of ₹150,000 within 90 days.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Goa
ROC-cum-Official Liquidator, Ministry of Corporate Affairs, Corporate Bhawan, EDC Complex, Plot No.21, Patto, Panaji, Goa, India, 403001
Phone: 0832-2438618/2438617 E-mail: roc.goa@mca.gov.in
Order ID: PO/ADJ/09-2025/GA/00650 Dated: 19/09/2025
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 12(8) OF THE COMPANIES ACT, 2013.
A. Appointment of Adjudicating Officer:
Ministry of Corporate Affairs vide its Gazette notification number S.O. 831(E) dated 24/03/20155 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 AURAELITE TECH PRIVATE LIMITED [herein after known as Company] bearing CIN
U46499GA2024PTC016952, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at H.No. SH-304, 3rd Floor Sai Plaza, Gomantak Times St Inez Tiswadi North Goa Goa India 403001
Individual details:
In the matter relating to ASHISH KESAVAT [herein after known as individual] having DIN 10855841 and having its address at VINOVA BASTI, ALANPUR KE PAAS, Sawaimadhopur Sawai Madhapur Rajasthan India 322021
In the matter relating to SANDEEP KESHAWAT [herein after known as individual] having DIN 10855842 and having its address at VINOVA BASTI, ALANPUR KE PAAS, Sawaimadhopur Sawai Madhapur Rajasthan India 322021
C. Provisions of the Act:
If any default is made in complying with the requirements of this section, the company and every officer who is in default shall be liable to a penalty of one thousand rupees for every day during which the default continues but not exceeding one lakh rupees
D. Facts about the case:
1. Default committed by the officers in default/noticee – This office has received a complaint w.r.t registered office of the company, the same was taken up with the company, however, the letter sent to the company has been returned undelivered to this office on 25.03.2025 with postal remark “Addressee Left”. Hence the company and its directors have violated the provision of section 12 of the Companies Act, 2013 and are liable for penal action under section 12(8) of the Companies Act, 2013 for non-maintenance of registered office of the company.
2. No e-hearing was requested by the company and its officers in default
E. Order:
1.1 This office has received a complaint against the company, the same was taken up with the company, however, the letter sent to the company has been returned undelivered to this office on 25.03.2025 with postal remark “Addressee Left”. Hence the company and its directors have violated the provision of section 12 of the Companies Act, 2013 and are liable for penal action under section 12(8) of the Companies Act, 2013 for non-maintenance of registered office of the company.
2 .In this regard, A Show Cause Notice vide notice ID no. SCN/ADJ/06-2025/GA/02070 dated 18.08.2025 was issued to the company and its officers in default under section 454 r/w section 12 of the Companies Act, 2013 through E-adjudication Module on account of failure to maintain the registered office of the company.
3. No reply has been filed by the company or its officers to the said notice issued by the Adjudicating Officer. The last date for filing reply to the notice was 02.09.2025.
4. In view of facts of the case, the Adjudicating Officer, in exercise of the powers conferred under the Companies Act, 2013, has imposed a penalty of Rs.50,000/- on the company and Rs.50,000/- each on the Officers in default for contravention of the provisions of section 12 of the Companies Act, 2013 for non-maintenance of registered of the company. It is noted that the said company qualifies as a Small Company in terms of the provisions of the Companies Act, 2013. Accordingly, in view of the applicability of section 446B of the Act, the penalties have been levied after granting the benefit of reduced penalty as prescribed therein.
5. Further, the company is directed to rectify the default by maintaining the registered office of the company in compliance with section 12 of the Companies Act, 2013.
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 | AURAELITE TECH PRIVATE LIMITED having CIN as U46499GA2024P TC016952 | 50000 | 0 | 100000 | |
| 2 | ASHISH
KESAVAT having DIN as 10855841 |
50000 | 0 | 100000 | |
| 3 | SANDEEP KESHAWAT having DIN as 10855842 |
50000 | 0 | 100000 |
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 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.
Trupti Sharma,
Registrar of Companies
ROC Goa
