The Registrar of Companies (ROC) Vijayawada, on October 10, 2025, issued an adjudication order imposing penalties on THREE SEASONS EXIM LIMITED and its three directors for multiple violations under the Companies Act, 2013. The penalty was adjudicated under Section 454 for the contravention of Section 450, the residual penalty clause, based on defaults identified in an inspection report. The core default stemmed from the company’s failure to adhere to the statutory requirements for conducting an Extraordinary General Meeting (EGM) held on May 4, 2017. Specifically, the inspection found that the company did not send the EGM notice to director Upendranath Nimmagadda, a violation of the notice requirements under Section 101 of the Act. Furthermore, the company was cited for not maintaining the General Meeting minutes in accordance with Section 101, suggesting a lapse in maintaining proper statutory records for the meeting.
The ROC’s order explicitly states that because the company violated the provisions of Section 101(3), which governs the service of notice of a general meeting, the penalties are imposed under Section 450 of the Act. Section 450 applies when no specific penalty is provided elsewhere in the Act for a contravention. Given the gravity of the oversight—failing to serve a formal meeting notice to a director and improperly maintaining minutes—the ROC imposed the maximum allowable non-continuing penalty under Section 450. The company was fined the maximum amount of ₹2,00,000. Concurrently, the three directors named as officers-in-default—Sai Raj Jampana, Padmavathi Jampana, and Bala Gandhi Raju Jampana—were each penalized the maximum officer penalty of ₹50,000. This results in a total penalty of ₹3,50,000 for the company and its directors. The penalized parties have 90 days to rectify the default and remit the fine through the MCA’s ‘e-Adjudication’ portal, with the directors explicitly directed to use their personal funds for their respective penalties.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Vijayawada
Registrar of Companies, 29-7-33, First Floor, Vishnuvardhanarao Street,
Suryaraopet, Vijayawada, Andhra Pradesh, India, 520002
Phone: 0866-2432347 E-mail: roc.vijayawada@mca.gov.in
Order ID: PO/ADJ/08-2025/VW/00590 Dated: 10/10/2025
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 THREE SEASONS EXIM LIMITED [herein after known as Company] bearing CIN U74900AP2014PLC095521, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at 65-9-1/C , OPP GPT MEHAR NAGAR 65-9-1/C , OPP GPT MEHAR NAGAR NA KAKINADA GUNTUR ANDHRA PRADESH INDIA 533004
Individual details:
In the matter relating to SAI RAJ JAMPANA [herein after known as individual] having DIN 06379136 and having its address at __________________ANDHRA PRADESH INDIA 533003
In the matter relating to PADMAVATHI JAMPANA [herein after known as individual] having DIN 01468976 and having its address at __________________ ANDHRA PRADESH INDIA 533003
In the matter relating to BALA GANDHI RAJU JAMPANA [herein after known as individual] having DIN 01469023 and having its address at __________________ ANDHRA PRADESH INDIA 533003
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 – As per the inspection report the company fails to send EGM notice dt. 04.05.2017 to Upendranath Nimmagadda, Director
2. As per the Inspection Report the IO has observed that the company for the EGM dated 04.05.2017 has not served General Meeting notice to Mr. Upendranath Nimmagadda and further the company has not maintained Geenral Meeting minutes as per section 101 of the Companies Act,2013.
E. Order:
1. As the company violated the provisions of section 101(3) of the Companies Act,2013. Hence the penalty imposed under 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 | THREE SEASONS EXIM LIMITED having CIN as U74900AP2014P LC095521 | 200000 | 200000 | 0 | 200000 |
| 2 | SAI RAJ
JAMPANA having DIN as 06379136 |
50000 | 50000 | 0 | 50000 |
| 3 | PADMAVATHI JAMPANA having DIN as 01468976 | 50000 | 50000 | 0 | 50000 |
| 4 | BALA GANDHI RAJU JAMPANA having DIN as 01469023 | 50000 | 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.
M. Varaprasad Rao,
Registrar of Companies
ROC Vijayawada
