The Registrar of Companies (ROC), Pune, passed an adjudication order under Section 454 of the Companies Act, 2013 for violation of Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014, punishable under Section 450 of the Act. The company had filed its consolidated financial statements for FY 2024–25 in Form AOC-4 XBRL on 2 January 2026, but mistakenly mentioned the date of the Annual General Meeting as 30 September 2025 instead of the correct date of 27 September 2025 due to a clerical or typographical error during data entry. The mistake was discovered during internal review and voluntarily reported through Form GNL-1 seeking adjudication. The director who digitally signed the form and the Chartered Accountant who certified it accepted that the error was inadvertent and without mala fide intent. After examining the records and replies, the adjudicating authority held that responsibility for accuracy lies with both the signatory and the certifying professional. Accordingly, a penalty of ₹10,000 each was imposed and the company was directed to file the corrected e-form.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Pune
PCNTDA Green Building, BLOCK A, 1st & 2nd Floor , Near Akurdi Railway Station, Akurdi, Pune, Maharashtra, India, 411044
Phone: 020-27651375,020-27651378
E-mail: roc.pune@mca.gov.in
Order ID: PO/ADJ/03-2026/PU/01736 | Dated: 11/03/2026
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, 2014for adjudging penalties under the provisions of this Act.
B. Company details:
In the matter relating to STEAM EQUIPMENTS LIMITED [herein after known as Company] bearing CIN U29119PN2004PLC019820, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at PLOT NO 44 TINY INDUSTRIALCO OP ESTATE LTD KONDHWA BUDRUK NA PUNE MAHARASHTRA INDIA 411048
Individual details:
In the matter relating to RASHEED SYED__________
In the matter relating to EJAZ AKHTER____________
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 – On perusal of the application submitted by the company in the Form GNL-1 vide SRN AC1440008 dated 20.01.2026 for adjudication of violation for violation of Rule 8 of Companies (The Registration Offices and Fees) Rules, 2014, wherein stated that the company has filed its consolidated financial statement for the FY 2024-25 in the Form AOC-4 XBRL vide SRN AC0938908 dated on 02.01.2026. due to an inadvertent clerical /typographical error during the data entry or preparation, the date of AGM was incorrectly mentioned as 30.09.2025 instead of the Actual date 27.09.2025. This error was identified during the internal review. Thus, the company has violated
provisions of Rule 8 of Companies (The Registration Offices and Fees) Rules, 2014 for which company and director who is in default are liable for penalized u/s 450 of the Companies Act 2013.
Rule 8 (3) of Companies (The Registration Offices and Fees) Rules, 2014 prescribed that the person certifying the e-form shall be responsible for the correctness of the contents of the e-form and correctness of the enclosures attached therewith.
Accordingly, you are hereby called upon to show cause as to why penal action under Section 454 of the Company Act, 2013 should not be initiated for the alleged violation of the provisions of Rule 8 of Companies (The Registration Offices and Fees) Rules, 2014 and you may submit objections/ reply, if any.
2. The company and the officers in default have not requested for e-hearing and the Adjudicating Officer is also of the view that the e-hearing is not required in the instant case.
E.Order:
1. a. An application was submitted by the company in Form GNL-1 vide SRN AC1440008 dated 20.01.2026 for adjudication of violation for violation of Rule 8 (3) of Companies (The Registration Offices and Fees) Rules, 2014, wherein it was admitted that the date of AGM was incorrectly mentioned. Accordingly, an adjudication notice was issued to the persons who had signed and certified the e-form and were responsible for the correctness of the contents and enclosures.
b. In the reply by the noticees, the default has been accepted, and it has been submitted that the error was purely inadvertent and technical, with no mala fide intent. The noticees have prayed for full waiver of the penalty on Mr. Ejaz Akhter, a practicing CA as he was engaged for XBRL tagging and certification based on data provided. It has been further prayed that the SCN be disposed of with no penalty (or only nominal on Mr. Rasheed Syed), considering voluntary disclosure, inadvertent nature, no financial/ default impact.
c. On perusal of the details available on MCA21 portal along with the application and replies by the officers in default , it is observed the company has filed its financial statement for the FY 2024-25 in Form AOC-4 XBRL vide SRN AC0938908 dated 02.01.2026, wherein the date of AGM was incorrectly mentioned as 30.09.2025 instead of the Actual date 27.09.2025. Further, the aforementioned E-form was digitally signed, and Declaration was given by RASHEED SYED, Director (having DIN as 01902862) and was certified by Mr. EJAZ AKHTER, Chartered Accountant.
d. Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 of the Act reads as under: 3. The authorized signatory and the professional, if any, who certify e-form shall be responsible for the correctness of the contents of e-form and correctness of the enclosures attached with the electronic form. Thus, the provision casts responsibility on both signatory, who signs the forms and the professional who certifies the eform.
e. Furthermore, the Company does not fall under proviso of Section 2(85) of the Act and is not eligible for benefit under Section 446B the Act.
f. Now, in exercise of the powers conferred on the undersigned vide Notification dated 24th March 2015 and having considered the replies submitted in response to the notice issued, I hereby impose the penalty on the officers in default for violation of Rule 8 (3) of Companies (The Registration Offices and Fees) Rules, 2014 punishable under section 450 of the Act as per the table given under.
g. It is hereby clarified that while filing new Form, the Company shall not cause any change in its earlier attachment which was filed in E-Form AOC-4 vide SRN AC0938908 on 02.01.2026. Further, it is also clarified that order is limited to rectifying the mistake in aforesaid E-form and shall have no consequence except rectification of the said E-form AOC-4 XBRL.
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 | RASHEED SYED having DIN as 01902862 | The company is directed to file the corrected eform. | 10000 | 0 | 50000 |
| 2 | EJAZ AKHTER having PAN as ADIPA2093E | 10000 | 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 Navi Mumbai 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.
Parvez Naikwadi,
Registrar of Companies
ROC Pune
