The Registrar of Companies (ROC), Gwalior, has issued an adjudication order against Asanjo Food Product Private Limited and its directors for violating Section 12(8) of the Companies Act, 2013. The case was initiated after a complaint was filed through the CPGRAMs portal, and a subsequent letter sent to the company’s registered office was returned with the remark “Talaash/Left,” indicating that the company was no longer operating from the listed address. Both a show cause notice and a hearing notice were issued to the company and its directors, but no one responded or appeared for the scheduled e-hearing.
Based on the company’s failure to maintain a registered office, the ROC determined that it had contravened the provisions of Section 12(1) of the Act, making it and its officers liable under Section 12(8). The default period was calculated from the date the letter was returned undelivered, June 16, 2025. While the standard penalty under the Act is ₹1,000 per day up to a maximum of ₹100,000, the company was classified as a “Small Company” under Section 2(85) of the Act. As a result, the penalty was reduced to one-half of the prescribed amount. Consequently, a penalty of ₹17,000 was imposed on the company, and ₹17,000 each on its directors, Manish Kumar Asrani and Santosh Asrani. The company and the officers have 90 days to pay the penalty, with the officers required to pay from their personal funds.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Chennai
Registrar Of Companies, Block No.6,B Wing 2nd Floor, Shastri Bhawan 26, Haddows Road, Chennai, Tamil Nadu, India,
600034
Phone: 044-28276652/28276654
E-mail: roc.chennai@mca.gov.in
Order ID: PO/ADJ/09-2025/GL/00661 | Dated: 18/09/2025
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 24/03/2015 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 ASANJO FOOD PRODUCT PRIVATE LIMITED [herein after known as Company] bearing CIN U15400MP2013PTC030890, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at H.NO. 361 KARIN LINE ACHARYA KRIPALANI WARD NA KATNI Katni Madhya Pradesh India 483501
Individual details:
In the matter relating to MANISH KUMAR ASRANI [herein after known as individual] having DIN 06567476 and having its address at KARINE LINE MADHAV NAGAR ACHARYA KRIPLANI WARD KATNI Madhya Pradesh India 483501
In the matter relating to SANTOSH ASRANI [herein after known as individual] having DIN 06567484 and having its address at KARINE LINE MADHAV NAGAR ACHARYA KRIPLANI WARD KATNI Madhya Pradesh India 483501
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 – An online complaint on CPGRAMs portal vide no. DCOYA/E/2025/0003299 dated 27.05.2025 has been received from Mr. Arjoo Jain against M/s Asanjo Food Product Private Limited. This office (ROC Gwalior) has sent a letter No. ROC-G/CPGRAMs/2025/305,306 dated 04.06.2025 to the said company, which was returned and received on 16.06.2025 to this office. The letter returned with postal authority with postal authority remark Talaash/Left.
2. No reply was received to the said Show Cause Notice dated 18.07.2025. Thus, an opportunity of being heard was granted by the Adjudicating Officer to the Company and its Officers in default under the provisions of Section 454(4) of the Act.
E. Order:
1. A. A Show Cause notice bearing ID: SCN/ADJ/07-2025/GL/02199 dated 18.07.2025 was issued to the Company and its Officers in default (hereinafter referred to as the notices) under Section 454 read with Section 12(8) of the Act.
B. However, no reply was received to the said Show Cause Notice dated 18.07.2025 and the SCN was returned back undelivered.
C. Thus, an opportunity of being heard was granted by the Adjudicating Officer to the Company and its Officers in default under the provisions of Section 454(4) of the Act. Accordingly, an E-hearing was scheduled on 12.09.2025 at 11:00 AM (IST) and notice bearing ID: EH/ADJ/08-2025/GL/00754 dated 20.08.2025 was issued. However, no one appeared for the said hearing.
D. Based on the facts and circumstances of the case, it is observed that the Company has failed to maintain its registered office at the aforementioned address in contravention of Section 12(1) of the Act. Thus, the Company and its every Officer who is in Default shall be liable under the provisions of Section 12(8) of the Act.
E. The period of default is considered from the date of the letter returned undelivered, that is 16.06.2025. Accordingly, the Company and its Officers in default shall be liable to a penalty of Rs. 1000/- per day for continued default, subject to a maximum penalty of Rs. 1,00,000/- (Rupees One Lakh only) each.
F. However, the Subject Company falls within the definition of a Small Company under the provisions of Section 2(85) of the Act as its paid-up capital is Rs. 18,46,910/- and its turnover is Rs. 29,25,52,577.10/- for the F.Y.2023-24. Therefore, as per the provisions of Section 446B of the Companies Act, 2013, the Company and the Officers in default shall be subject to penalty which shall not be more than one half of the prescribed penalty, that is Rs. 17,000/- ( Seventeen Thousand Only) each in the instant case.
G. Now, in exercise of the powers conferred on the Adjudicating Officer vide Notification dated 24th March 2015, I hereby impose penalty of Rs.17,000/- (Seventeen Thousand Only) on the Company and its Officers in default namely Shri Manish Kumar Asrani (DIN: 06567476) and Shri Santosh Asrani (DIN: 06567484) under Section 12(8) read with Section 446B of the Act.
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 | ASANJO FOOD PRODUCT PRIVATE LIMITED having CIN as U15400MP2013P TC030890 | 17000 | 0 | 100000 | |
| 2 | MANISH KUMAR ASRANI having DIN as 06567476 | 17000 | 0 | 100000 | |
| 3 | SANTOSH ASRANI having DIN as 06567484 | 17000 | 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 Ahmedabad 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.
Mukesh Kumar Soni,
Registrar of Companies
ROC Gwalior
