Failure to Disclose CIN in Annual Reports Attracts Maximum Penalty

The Registrar of Companies, Coimbatore passed an adjudication order under section 454 of the Companies Act, 2013, holding that the company had violated section 12(3)(c) by failing to disclose its Corporate Identification Number (CIN) in its Annual Reports for ten consecutive financial years from 2013–14 to 2022–23. The Annual Reports, circulated to shareholders and other stakeholders, were held to be “official publications” within the meaning of the Act. The company’s defence that there was ambiguity regarding the scope of official publications was rejected as unsustainable. The adjudicating authority concluded that the omission constituted a statutory contravention and imposed the maximum penalty of ₹1 lakh on the company and ₹1 lakh each on all officers in default, including the managing director, whole-time director, company secretary, and chief financial officer. The officers were directed to rectify the default, pay the penalties from personal sources within 90 days, and were informed of their right to appeal before the Regional Director.

GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Coimbatore
Registrar Of Companies, No.7, AGT Business Park, I Floor, Phase II, Avinashi Road, Civil Aerodrome Post, Coimbatore,
Tamil Nadu, India, 641014
Phone: (0422) -2629640,2628170
Fax: 0422-2628089
E-mail: roc.coimbatore@mca.gov.in

Order ID: PO/ADJ/01-2026/CB/01376 Dated: 12/01/2026

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 SRI RAMAKRISHNA MILLS (COIMBATORE) LIMITED————

Individual details:

In the matter relating to KRISHNAKUMAR GOPALSWAMY —

In the matter relating to SRIKANTAN ANANTHA SUBRAMANIAN ——-

In the matter relating to MURALIKRISHNAN SRIVIDYA——–

In the matter relating to DORAISWAMI LAKSHMINARAYANASWAMY ——–

In the matter relating to NAGASWARNA LAKSHMINARAYANASWAMY ——-

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 – Company is supposed to display its CIN in every official publication/letter heads/notices etc. However it is observed that the Annual Reports for the financial years 2013-14 to 2022­23 of the company which is supposedly circulated to all its shareholders do not contain the CIN of the company in the page or wherever addresses of the company is displayed.

2. Company has violated section 12(3)(c) of Companies Act 2013 by not printing CIN number of the Company in its Official Publications viz Annual Report of the Company. An adjudication notice was sent to the Company seeking their reply / comments. The Company and Officers in Default has replied that there is ambiguity on what constitutes “Official Publications” and hence they are of the genuine belief that the Annual Reports of the Company does not come under Official Publication. The reply of the company is not satisfactory as the Annual Report is supposed to be an authentic official publication reaching 1000s of shareholders of the Company and agencies like the Stock Exchanges etc. Hence e-Hearing was scheduled. Based on Company’s request physical hearing was conducted on 12/01/2026 and orders passed.

E. Order:

1. The contravention under section 12 is established as the Company has not published the CIN number in its publication, thus not in line with provisions of section 12(3)(c) of Companies Act 2013. Hence a penalty of Rs. 1.0 Lakh for the Company and all the Officers in Default viz the MD, WTD, CS and CFO.

2. The details of penalty imposed on the company, officers in default and others are shown in the table below:

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 Chennai 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.

Vairamuthu Nagarajan,
Registrar of Companies
ROC Coimbatore