SEN HON LEE TECHNOLOGIES and its directors failed to consecutively number pages and record dates of minutes for AGMs held on 31.12.2020 and 30.11.2021, violating Section 118(11) read with Secretarial Standard-2. ROC Kanpur imposed penalties of ₹25,000 on the company and ₹5,000 per officer, highlighting directors’ compliance responsibility.
The Registrar of Companies (ROC), Kanpur, issued an Adjudication Order (dated 13/10/2025) against SEN HON LEE TECHNOLOGIES PRIVATE LIMITED and its three officers in default—Wu Xiaoping, Huang Weifei, and Gautam Singh. The order cites a violation of Section 118 of the Companies Act, 2013, concerning the proper maintenance of minute books. Specifically, an inquiry identified two contraventions related to Secretarial Standard-2 (SS-2) for the Annual General Meetings (AGMs) held on December 31, 2020, and November 30, 2021. The deficiencies included the failure to ensure consecutive numbering of pages in the Minutes Books (SS-2, point 17.1.4) and the failure to record the date of entry of the Minutes as required by the Company Secretary or authorized person (SS-2, point 17.4.2). These lapses in statutory record-keeping led to penal action under Section 118(11) of the Act.
Following the issuance of a Show Cause Notice on June 24, 2025, the ROC recorded that neither the company nor the officers in default provided any response to the notice or requested a hearing. Consequently, the Adjudicating Officer proceeded to impose the prescribed penalties under Section 118(11). The company, SEN HON LEE TECHNOLOGIES PRIVATE LIMITED, was fined the maximum penalty of ₹25,000. Concurrently, each of the three officers in default was individually penalized the maximum amount of ₹5,000. The total penalty imposed on the company and its directors for these non-compliances concerning the minute books totals ₹40,000.
The order mandates that the company and its officers must rectify the default immediately, which entails bringing the minute books into full compliance with Section 118 and SS-2. They are required to pay the total penalty amount within 90 days of receiving the official order. The penalties imposed on the individual directors must be remitted from their personal sources of income using the Ministry of Corporate Affairs’ ‘e-Adjudication’ portal. The order also informs the noticees that they have the option to file an appeal with the Regional Director, RD Noida, within a period of sixty days from the date of receipt, utilizing Form ADJ, and emphasizes the penal consequences under Section 454(8) for failure to remit the penalty within the stipulated deadline.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Kanpur
Registrar of Companies, 37/17, Westcottt Buidling, The Mall, Kanpur, Uttar Pradesh, India, 208001
Phone: 0512-2310443,2310227,2310323
E-mail: roc.kanpur@mca.gov.in
Order ID: PO/ADJ/10-2025/KN/00761 Dated: 13/10/2025
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 118(11) 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 SEN HON LEE TECHNOLOGIES PRIVATE LIMITED [herein after known as Company] bearing CIN U25209UP2019PTC117599, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at PLOT NO 10, KASNA ECOTECH -1 EXTENSION -1 NA GREATER NOIDA GAUTAM BUDDHA NAGAR UTTAR PRADESH INDIA 201308
Individual details:
In the matter relating to WU XIAOPING [herein after known as individual] having DIN 08602212 and having its address at NO 301 UNIT 2 BUILDING 17 NO 95 SECTION 3 OF JIANGNAN ROAD JIANGYANG DISTRICT LAUZHOU CITY SICHUAN NA CHINA 646000
In the matter relating to HUANG WEIFEI [herein after known as individual] having DIN 08517634 and having its address at NO.18 QIAOTOUYUAN, DAQIAOBIAN VILLAGE GUISHAN TOWNSHIP HUBEI PROVINCE MACHENG CITY NA CHINA 438300
In the matter relating to GAUTAM SINGH [herein after known as individual] having DIN 08575001 and having its address at GUDHANA VISHARAT NAGAR BISHARAT NAGAR BUDAUN UTTAR PRADESH INDIA 243637
C. Provisions of the Act:
(11) If any default is made in complying with the provisions of this section in respect of any meeting, the company shall be liable to a penalty of twenty-five thousand rupees and every officer of the company who is in default shall be liable to a penalty of five thousand rupees.
D. Facts about the case:
1. Default committed by the officers in default/noticee – The Directorate vide its letter no. Inq./Guard/2021/10971 dated 17.12.2021 and Ministry?s letter no. F.No. CL-II-08/131/2021-DGCoA-MCA dated 13.12.2021 directed to conduct the inquiry u/s. 206(4) of the Companies Act, 2013, against the said company. On examining the minutes of general meetings it was found that i) As per point no.17.1.4 of Secretarial Standard-2, the pages of the Minutes Books shall be consecutively numbered. However, the same has not been compiled for AGM dated 31.12.2020 and 30.11.2021. ii) As per point no. 17.4.2 of Secretarial Standard-2, the date of entry of the Minutes in the Minutes Book shall be recorded by the Company Secretary. Where there is no Company Secretary, it shall be entered by any other person duly authorized by the Board or by the Chairman. The Company has not complied with the same for AGM dated 31.12.2020 and 30.11.2021. Accordingly, the said violation was reported by the Inquiry officer in report dated 08.06.2022. The O/o DGCoA vide its letter No. CL-II-04/190/2022-O/o DGCoA dated 12.08.2024 has accorded the sanction to take penal action. Thus, it is evident that the company and its Directors have failed to comply with the provisions of section 118 (10) of the Companies Act, 2013. And are thus liable for penal provisions.
2. Neither any response has been received from the company and its officers-in-default nor any request of hearing received in this regard.
E. Order:
1. This office issued Show Cause Notice on 24.06.2025 to the company and its officer-in-default as the Company has failed to maintain proper minute book in terms of Section 118 of the Companies Act, 2013 read with Secretarial Standard-2 due to the following:
i)Point no.17.1.4 of Secretarial Standard-2, the pages of the Minutes Books shall be consecutively numbered. However, the same has not been complied for AGM held on 31.12.2020 and 30.11.2021.
ii)Point no. 17.4.2 of Secretarial Standard-2, the date of entry of the Minutes in the Minutes Book shall be recorded by the Company Secretary, where there is no Company Secretary, it shall be entered by any other person duly authorized by the Board or by the Chairman. The Company has not complied with the same for AGM held on 31.12.2020 and 30.11.2021. More than 15 days have expired from issue of Show Cause Notice, no response has been received till date. The company and its officer-in default have also not requested for hearing. In the said circumstances, penalty as applicable as mentioned below is being imposed upon the company as well as its officer-in default as per Section 118 (11) 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 | SEN HON LEE TECHNOLOGIES PRIVATE LIMITED having CIN as U25209UP2019P TC117599 | 25000 | 0 | 25000 | |
| 2 | WU XIAOPING having DIN as 08602212 | 5000 | 0 | 5000 | |
| 3 | HUANG WEIFEI having DIN as 08517634 | 5000 | 0 | 5000 | |
| 4 | GAUTAM SINGH having DIN as 08575001 | 5000 | 0 | 5000 |
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 Noida 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.
Sanjay Bose,
Registrar of Companies
ROC Kanpur
