The Ministry of Corporate Affairs, through the Registrar of Companies, Kanpur, passed an adjudication order under Section 454 of the Companies Act, 2013 for violation of Rule 25A of the Companies (Incorporation) Rules, 2014, read with Section 450 of the Act. The company failed to file e-Form INC-22A (ACTIVE), which is mandatory for companies incorporated on or before 31 December 2017 to verify particulars of the company and its registered office. The default was identified during an inspection conducted under Section 206(5), reported in November 2022, and later acted upon following directions from the competent authority. Despite issuance of a show cause notice, neither the company nor its officers responded or sought a hearing. Consequently, the Registrar imposed the maximum statutory penalty of ₹2,00,000 on the company and ₹50,000 each on four officers in default. The order directs rectification of the default and payment of penalties within 90 days, while also providing a statutory right of appeal.
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/01-2026/KN/01430 | Dated: 23/01/2026
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 450 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 KARMBHOOMI INFRATECH REALITY LIMITED [herein after known as Company] bearing CIN U70102UP2013PLC056094, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at FLAT NO. 412-C, ASHOKA HEIGHTS, GANESHRA ROAD, NH-2, MATHURA (U.P.) NA MATHURA MATHURA UTTAR PRADESH INDIA 281001
Individual details:
In the matter relating to MANOJ KUMAR SENGAR ____________
In the matter relating to SARDAR SINGH ____________
In the matter relating to MAHIPAL SINGH ____________
In the matter relating to DEVENDRA PAL SINGH ____________
C. Provisions of the Act:
If a company or any officer of a company or any other person contravenes any of the provisions of this Act or the rules made thereunder, or any condition, limitation or restriction subject to which any approval, sanction, consent, confirmation, recognition, direction or exemption in relation to any matter has been accorded, given or granted, and for which no penalty or punishment is provided elsewhere in this Act, the company and every officer of the company who is in default or such other person shall be 1[liable to a penalty of ten thousand rupees, and in case of continuing contravention, with a further penalty of one thousand rupees for each day after the first during which the contravention continues, subject to a maximum of two lakh rupees in case of a company and fifty thousand rupees in case of an officer who is in default or any other person]
D. Facts about the case:
1. Default committed by the officers in default/noticee – RDNR vide letter dated 24.09.2021 directed to conduct the inspection u/s. 206(5) of the Companies Act, 2013. During the Couse of Inspection, Inspecting Officer has observed/pointed out that ?Rule 25A of the Companies (Incorporation) Rules, 2014 states that every company incorporated on or before the 31st of December 2017 shall file the particulars of the company and its registered office, in e-Form INC-22A- ACTIVE (Active Company Tagging Identities and Verification). However, it has been observed from the MCA Registry that the company has failed to file e-form INC 22A. Hence, it is a violation of Rule 25A of the Companies (Incorporation) Rules, 2014 read with Section 450 of the Companies Act, 2013?. The said violation was reported by the Inspecting Officer in his report dated 22.11.2022. Accordingly, the office of DGCoA vide its File No. CL-II-01/221/2023-O/o DGCoA-MCA dated 07.08.2024 directed this office to take necessary action for non-compliance of Rule 25A of the Companies (Incorporation) Rules, 2014 read with Section 450 of the Companies Act, 2013
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. Rule 25A of the Companies (Incorporation) Rules, 2014 states that every company incorporated on or before the 31st of December 2017 shall file the particulars of the company and its registered office, in e-Form INC-22A- ACTIVE (Active Company Tagging Identities and Verification). However, it has been observed from the MCA Registry that the company has failed to file e-form INC 22A. Hence, it is a violation of Rule 25A of the Companies (Incorporation) Rules, 2014 read with Section 450 of the Companies Act, 2013
This office issued Show Cause Notice on 23.10.2025 more than 30 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 as per Section 450 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 | KARMBHOOMI INFRATECH REALITY LIMITED having CIN as U70102UP2013P LC056094 | 200000 | 0 | 200000 | |
| 2 | MANOJ KUMAR SENGAR having DIN as 03031042 |
50000 | 0 | 50000 | |
| 3 | SARDAR SINGH having DIN as 02477583 | 50000 | 0 | 50000 | |
| 4 | MAHIPAL SINGH having DIN as 05308568 | 50000 | 0 | 50000 | |
| 5 | DEVENDRA PAL SINGH having DIN as 01832091 | 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 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
