On 12th November 2025, ROC Gwalior issued an adjudication order under Section 454 of the Companies Act, 2013 against Xtranet Technologies Limited and its directors for violating Section 42(9) of the Act. The company failed to file its return of allotment in Form PAS-3 within 15 days from the date of allotment and attached a valuation report from a merchant banker instead of a registered valuer, contrary to Rule 13(2)(g) of the Companies (Share Capital and Debentures) Rules, 2014. The period of default was from 26th March 2023 to 11th May 2023. Consequently, the company and its officers in default—Jogendrapal Singh Alagh and Sukhbir Singh Kukreja—were each penalized ₹47,000. They were directed to rectify the default and pay the penalties through the MCA e-Adjudication portal within 90 days. Appeals can be filed with the Regional Director within 60 days. Non-payment may lead to further penal consequences under Section 454(8) of the Act.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Gwalior
Registrar Of Companies, 3rd Floor, ‘A’ Block, Sanjay Complex, Jayendra Ganj, Gwalior, Madhya Pradesh, India, 474009
Phone: 0751-2321907 Fax: 0751-2631853
E-mail: roc.gwalior@mca.gov.in
Order ID: PO/ADJ/11-2025/GL/00847 | Dated: 12th November 2025
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 42(9) 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 XTRANET TECHNOLOGIES LIMITED [herein after known as Company] bearing CIN
U72200MP2002PLC014956, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at Z-24, ZONE – 1, M.P. NAGAR NA BHOPAL BHOPAL MADHYA PRADESH INDIA 462011
Individual details:
In the matter relating to JOGENDRAPAL SINGH ALAGH [herein after known as individual] having DIN 00411418 and having its address at ________
In the matter relating to SUKHBIR SINGH KUKREJA [herein after known as individual] having DIN 00411525 and having its address at ________
C. Provisions of the Act:
If a company defaults in filing the return of allotment within the period prescribed under sub-section (8), the company, its promoters and directors shall be liable to a penalty for each default of one thousand rupees for each day during which such default continues but not exceeding twenty-five lakh rupees.
D. Facts about the case:
1. Default committed by the officers in default/noticee – 1.The company XTRANET TECHNOLOGIES LIMITED (CIN: U72200MP2002PLC014956) has filed suo-moto an application of Adjudication under section 454 of the Companies Act, 2013 for Adjudication of Penalties for Non-compliance of Section 42 of the companies Act, 2013 through the e-Form GNL-1 vide SRN: AB6387524 on 30.08.2025. This office has verified the facts and found that the company has violated the provision of section 42 of Companies Act 2013 as the company did not file its return of allotment within 15 days from the date of allotment and the applicant company had inadvertently attached the valuation report issued by the Merchant Banker instead of the valuation report issued by the Registered Valuer while filing E-Form PAS-3 with the Registrar. As per Rule 13(2)(g) of Companies (Share capital and Debentures) Rules, 2014 the company shall attach to the Return of allotment in Form PAS-3 ?a copy of the Valuation report of the registered Valuer?.
2. The company has filed an application dated 28.08.2025, accordingly the matter has been taken up and opportunity of being heard has been given to the applicants on 11.11.2025
E. Order:
1. A. A Show Cause notice bearing ID: SCN/ADJ/10-2025/GL/02654 dated 08.10.2025 was issued to the Company and its Officers in default (hereinafter referred to as the notices) under Section 454 For Non-Compliance of Section 42 of the Act.
B. The company had submitted its written submission on 10.11.2025 to the said Show Cause Notice dated 08.10.2025.
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 11.11.2025 at 12:00 PM (IST) and notice bearing ID: EH/ADJ/11-2025/GL/00881 dated 10.11.2025 was issued. The authorised representative on behalf of the company appeared and attended the hearing.
D. Based on the facts and circumstances of the case, it is observed that the Company has violated the provision of section 42(9) of Companies Act 2013 as the company did not file its return of allotment within 15 days from the date of allotment and the applicant company had inadvertently attached the valuation report issued by the Merchant Banker instead of the valuation report issued by the Registered Valuer while filing E-Form PAS-3 with the Registrar. As per Rule 13(2)(g) of Companies (Share capital and Debentures) Rules, 2014 the company shall attach to the Return of allotment in Form PAS-3 a copy of the Valuation report of the registered Valuer.
E. The period of default is considered from the 26.03.2023 to11.05.2023. Accordingly, If a company defaults in filing the return of allotment within the period prescribed under sub-section (8), the company, its promoters and Directors shall be liable to a penalty for each default of one thousand rupees for each day during which such default continues but not exceeding twenty-five lakh rupees.
F. Further, the Subject Company is not falling within the definition of a Small Company under the provisions of Section 2(85) of the Act.
G. Now, in exercise of the powers conferred on the Adjudicating Officer vide Notification dated 24th March 2015, I hereby impose penalty of Rs.47,000/- (Forty Seven Thousand Only) on the Company and its Officers in default namely Shri Jogendrapal Singh Alagh (DIN: 00411418) and Shri Sukhbir Singh Kukreja (DIN: 00411525).
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 | XTRANET TECHNOLOGIES LIMITED having CIN as U72200MP2002P LC014956 | 47000 | 0 | 2500000 | |
| 2 | JOGENDRAPAL SINGH ALAGH having DIN as 00411418 | 47000 | 0 | 2500000 | |
| 3 | SUKHBIR SINGH KUKREJA having DIN as 00411525 |
47000 | 0 | 2500000 |
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
