The Registrar of Companies (ROC), Goa, issued an Adjudication Order (dated 16/10/2025) under the Companies Act, 2013, imposing a collective penalty of ₹4,00,000 on INDU PACKAGING (DAMAN) LIMITED and its three directors: Vyoma Hemendra Sheth, Hemendra Himatlal Sheth, and Samarth Hemendra Sheth. The penalty was levied for violating Section 12(3)(c), which requires every company to prominently display its Corporate Identification Number (CIN) along with other key details on all business letters, billheads, letter papers, and official publications. An inquiry conducted by the ROC revealed a sustained pattern of non-compliance, specifically finding that the company failed to include its CIN on the letterheads of the Director’s Report for the Financial Year (FY) 2016-17 and on the Financial Statements for FY 2015-16, FY 2016-17, and FY 2017-18. This lapse constitutes a failure to uphold fundamental corporate disclosure requirements.
The contravention was penalized under Section 12(8) of the Act, which allows for a penalty of ₹1,000 per day of default, subject to a maximum of ₹1,00,000 per defaulting party. Despite the issuance of a Show Cause Notice on September 9, 2025, neither the company nor the three officers in default provided any response or communication to the ROC. Given the absence of a reply, the Adjudicating Officer proceeded to impose the maximum penalty on every entity involved: ₹1,00,000 on the company and ₹1,00,000 on each of the three directors, resulting in the total penalty of ₹4,00,000. The order mandates the company and the directors to immediately rectify the default by ensuring the CIN is displayed on all requisite documents. The penalties must be paid through the MCA’s ‘e-Adjudication’ portal within 90 days of receiving the order, with the directors explicitly required to use their personal funds for payment. The order also informs the penalized parties of their right to appeal the decision to the Regional Director, RD Mumbai, within sixty days, emphasizing that Section 454(8) details the consequences for failure to pay the fine within the statutory time limit.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Goa
ROC-cum-Official Liquidator, Ministry of Corporate Affairs, Corporate Bhawan, EDC Complex, Plot No.21, Patto, Panaji,
Goa, India, 403001
Phone: 0832-2438618/2438617
E-mail: roc.goa@mca.gov.in
Order ID: PO/ADJ/10-2025/GA/00721 Dated: 16/10/2025
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 12(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 with Companies (Adjudication of Penalties) Rules, 2014 for adjudging penalties under the provisions of this Act.
B. Company details:
In the matter relating to INDU PACKAGING (DAMAN) LIMITED [herein after known as Company] bearing CIN U74950DD1996PLC002159, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at PLOT NO16 GDDIC INDUSTRIALESTATE SOMNATH ROAD DAMAN NA DAMAN DAMAN AND DIU INDIA 396210
Individual details:
In the matter relating to VYOMA HEMENDRA SHETH [herein after known as individual] having DIN 00328449 and having its address at
In the matter relating to HEMENDRA HIMATLAL SHETH [herein after known as individual] having DIN 00331653 and having its address at
In the matter relating to SAMARTH HEMENDRA SHETH [herein after known as individual] having DIN 03596648 and having its address at
C. Provisions of the Act:
If any default is made in complying with the requirements of this section, the company and every officer who is in default shall be liable to a penalty of one thousand rupees for every day during which the default continues but not exceeding one lakh rupees
D. Facts about the case:
1. Default committed by the officers in default/noticee – As per the Section 12(3)(c) of the Companies Act, 2013, every company shall get its name, address of its registered office and CIN alongwith telephone number, fax number, if any, email and website addresses, if any, printed in all its business letters, billheads, letter papers and in all its notices and other official publications.
During the course of Inquiry, it was observed by the Inquiry Officer that the company has failed to mention its CIN on its letterheads of the Director report for the FY 2016-17 as well as on the letterheads of the financial statements for FY 2015-16, FY 2016-17 & 2017-18. The company has failed to comply with section 12(3)(C) of the Companies Act, 2013. Therefore, the company and its officers in default are liable for penal action under section 12(8) of the Companies Act, 2013.
E. Order:
1. During the course of Inquiry, it was observed by the Inquiry Officer that the company has failed to mention its CIN on its letterheads of the Director report for the FY 2016-17 as well as on the letterheads of the financial statements for FY 2015-16, FY 2016-17 & 2017-18. The company has failed to comply with section 12(3)(C) of the Companies Act, 2013. Therefore, the company and its officers in default are liable for penal action under section 12(8) of the Companies Act, 2013
2. In this regard, A Show Cause Notice vide notice ID no. : SCN/ADJ/05-2025/GA/01231 dated 09.09.2025 was issued to the company and its officers in default under section 454 r/w section 12 of the Companies Act, 2013 through E-adjudication Module, for failure to comply with the said provisions. However, no reply has been received from the company and its officers in default.
3.After considering the facts of the case, the Adjudicating Officer, in exercise of the powers conferred under the Companies Act, 2013, has imposed a penalty of Rs.1,00,000/- on the company and Rs.1,00,000/- each on officers in default for contravention of section 12(3)(c) the Companies Act, 2013.
4. 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 | INDU PACKAGING (DAMAN) LIMITED having CIN as U74950DD1996P LC002159 | 100000 | 0 | 100000 | |
| 2 | VYOMA HEMENDRA SHETH having DIN as 00328449 | 100000 | 0 | 100000 | |
| 3 | HEMENDRA HIMATLAL SHETH having DIN as 00331653 | 100000 | 0 | 100000 | |
| 4 | SAMARTH HEMENDRA SHETH having DIN as 03596648 | 100000 | 0 | 100000 |
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 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.
Trupti Sharma,
Registrar of Companies
ROC Goa
