ROC Bangalore imposed penalties under Section 134(8) for non-disclosure of mandatory information in the company’s Board Report for FY 2018–19. The order reaffirms that incomplete disclosures, even if unintentional, attract penalties under the Companies Act.
The Registrar of Companies (ROC), Bangalore, issued an Adjudication Order (Order ID: PO/ADJ/10-2025/BL/00792) against REWARD360 GLOBAL SERVICES PRIVATE LIMITED (CIN U74900KA2012PTC067399) and two of its directors, Amit Tribhuvan Chawla (DIN 03608520) and Dekyi Yangtso Khangsar (DIN 03614446). The order addresses a violation of Section 134(8) of the Companies Act, 2013, specifically related to the Board of Directors’ failure to provide requisite disclosures in the Board Report for the financial years 2018-19, 2019-20, and 2020-21. The company filed the adjudication application suo-motu (on its own initiative) on September 27, 2024, citing various reasons for the non-compliance, including the prevailing COVID-19 situation during the relevant period.
Following the application, a show cause notice and subsequent e-hearing were held. During the proceedings, the company and officers in default submitted that the violation was unintentional and asserted the company’s otherwise compliant history. The Adjudicating Officer confirmed that REWARD360 GLOBAL SERVICES PRIVATE LIMITED does not meet the definition of a small company under Section 2(85) of the Act. Consequently, the provision for imposing a lesser penalty under Section 446B was not applicable to the case. The adjudication was processed collectively for the three financial years, although this specific order pertains to FY 2018-19.
The total penalty imposed under the relevant statutory limits amounts to ₹4,00,000. The company was penalized ₹3,00,000, which is the maximum limit for the company under the provision. Each of the two officers in default—Amit Tribhuvan Chawla and Dekyi Yangtso Khangsar—was penalized ₹50,000. The officers were specifically directed to pay the penalty amount from their personal sources/income. The company and the officers are required to pay the respective penalties and rectify the underlying default within 90 days of receiving the order. Non-compliance with the payment deadline will result in further penal action as per Section 454(8).
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Bangalore
Registrar Of Companies, ‘E’ Wing, 2nd Floor, Kendriya Sadana, Kormangala, Bangalore, Karnataka, India, 560034
Phone: 080-25633105,080-25537449
E-mail: roc.bangalore@mca.gov.in
Order ID: PO/ADJ/10-2025/BL/00792 | Dated: 17/10/2025
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 134(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 witCompanies (Adjudication of Penalties) Rules, 2014 for adjudging penalties under the provisions of this Act.
B. Company details:
In the matter relating to REWARD360 GLOBAL SERVICES PRIVATE LIMITED [herein after known as Company] bearing CIN U74900KA2012PTC067399, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at FORTUNE SUMMIT IT PARK, 06TH FLOOR, 290/281/276/243/244, SECTOR 6, HSR LAYOU FORTUNE SUMMIT IT PARK, 06TH FLOOR, 290/281/276/243/244, SECTOR 6, HSR LAYOU NA BENGALURU BANGALORE KARNATAKA INDIA 560068
Individual details:
In the matter relating to AMIT TRIBHUVAN CHAWLA [herein after known as individual] having DIN 03608520 and having its address at
In the matter relating to DEKYI YANGTSO KHANGSAR [herein after known as individual] having DIN 03614446 and having its address at
C. Provisions of the Act:
(8) If a company is in default in complying with the provisions of this section, the company shall be liable to a penalty of three lakh rupees and every officer of the company who is in default shall be liable to a penalty of fifty thousand rupees
D. Facts about the case:
1. Default committed by the officers in default/noticee – The company has filed this adjudication application on 27.09.2024 for violation of the provisions of section 134(1) and 134(3) of the Act by its Board of directors for failure to provide disclosures in the Board report for the financial years 2018-19.
2. The company and officers in default asked for a hearing and same was provided. The order is issued based on the application, notice for adjudication, replies received and submission made at the time of hearing.
E. Order:
1. The company has filed an adjudication application on 27.09.2024 for violation of the provisions of section 134 of the Act by its Board of directors for failure to provide certain disclosures in the Board report for the financial years 2018-19, 2019-20 and 2020-21, including those related to the consolidated financials of the company. The reasons cited were multifarious including the then prevalent COVID situation. Pursuant to the adjudication application filed by the company, show cause notice dated 19.02.2025 was sent to the company and its officers in default through e-Adjudication module, and was also sent through speed post on 28.02.2025. The company and Officers in default have submitted their reply dated 14.03.2025 on e-Adjudication portal stating that the violation was unintentional and the company is otherwise a compliant company. They submit that this application has been filed suo-motu by them. Subsequently, e-hearing notice dated 23.06.2025 was sent to the company and its officers in default through e-Adjudication module. E- Hearing was scheduled on 24.06.2025 which was attended by Mr. Naman G Joshi, practising company secretory and authorized representative of company and officers in default who made the submissions as per the adjudication application filed and reiterated the same.
It is seen from records that the company does not fall under the definition of small company as per the provisions of section 2(85) of the Companies Act, 2013. Therefore, the provision of imposing lesser penalty as per the section 446B of the Act shall not be applicable in the case.
This violation is being adjudicated for the 3 financial years viz. 2018-19, 2019-20 and 2020-21 on this day through the adjudication order. However, in the e-Adjudication Module, this Order pertains to the FY 2018-19, and other financial years are dealt with in separate Orders.
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 | REWARD360 GLOBAL SERVICES PRIVATE LIMITED having CIN as U74900KA2012P TC067399 | 300000 | 0 | 300000 | |
| 2 | AMIT TRIBHUVAN CHAWLA having DIN as 03608520 | 50000 | 0 | 50000 | |
| 3 | DEKYI YANGTSO KHANGSAR having DIN as 03614446 | 50000 | 0 | 50000 |
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 Hyderabad 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.
Simhachalam Naidu,
Registrar of Companies
ROC Bangalore
