The Registrar of Companies, Gwalior, passed an adjudication order under Section 454 of the Companies Act, 2013 against Shreekrishna Impex Ventures Limited and its directors for non-compliance relating to incorrect disclosures in Form MGT-7A for FY 2021–22. The company failed to properly record a board meeting noting a director’s resignation, incorrectly reported directors’ attendance, and attached an erroneous shareholding list in its annual return, thereby violating Section 92 and attracting penalty under Section 450. Although the company filed a suo-motu adjudication application and participated in the hearing, the Adjudicating Officer held that the contraventions were established from the date of filing the defective form (19.10.2022). As the company qualified as a “small company” under Section 2(85), reduced penalties under Section 446B were applied. Consequently, a penalty of ₹1,00,000 was imposed on the company and ₹25,000 each on the officers in default, payable within 90 days, with a right of appeal to the Regional Director.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Gwalior
Registrar Of Companies, 3rd Floor, ‘A’ Block, Sanjay Complex, Jayendra Ganj, Gwalior, Madhya Pradesh, India, 474009
Phone: 0751-2321907
Fax: 0751-2631853
E-mail: roc.gwalior@mca.gov.in
Order ID: PO/ADJ/02-2026/GL/01664 | Dated: 16/02/2026
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 SHREEKRISHNA IMPEX VENTURES LIMITED [herein after known as Company] bearing CIN U52190MP2020PLC050793, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at 7TH FLOOR, SE- 020-022, BANSAL ONE RANI KAMLAPATI RAILWAY STATION, E2 SECTOR HUZUR BHOPAL MADHYA PRADESH INDIA 462016
Individual details:
In the matter relating to ASHISH AGARWAL……………
In the matter relating to RAKESH AGRAWAL………..
In the matter relating to SHIRISH RAMESH AGARWAL………….
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 – The company SHREEKRISHNA IMPEX VENTURES LIMITED (CIN: U52190MP2020PLC050793) has filed suo-moto an application of Adjudication under section 454 of the Companies Act 2013 for Adjudication of Penalties for Non-compliance of Provisions of the companies Act, 2013. This office has verified the facts and found that the company has violated the provisions of the Companies Act 2013, liable to penalty under section 450 of the companies Act 2013 by making non-compliances in the Financial Year 2021-22 as in the meeting dated 31.03.2022 held for taking note of the resignation of Mr. Shirish Agarwal has been left to be incorporated in segment VIII. ?Meetings of Members/Class of Members/Board/Committees of the Board of Directors? and in sub-segment B ?Board Meetings? the e-form MGT-7A and conrequently the attendance of the directors in the Sub segment C ?Attendance of Directors? has also been wrongly mentioned. Further wrong list of shareholding has also been attached in the said e-form.
2. The company has filed an application dated 06.10.2025, accordingly the matter has been taken up and opportunity of being heard has been given to the applicants on 04.02.2026.
E. Order:
1. A. A Show Cause notice bearing ID: SCN/ADJ/12-2025/GL/03087 dated 16.12.2025 was issued to the Company and its Officers in default (hereinafter referred to as the notices) under Section 454 for adjudication of penalties for non-compliance of Section 92 of the Act.
B. The company has filed an application dated 06.10.2025, accordingly the matter has been taken up and an opportunity of being heard was granted by the Adjudicating Officer to the Company and its Officers in default under the provisions of Section 454(4) of the Act. Accordingly, an E-hearing was scheduled on 04.02.2026 at 01:00 PM (IST) and notice bearing ID: EH/ADJ/01-2026/GL/01139 dated 20.01.2026 was issued. The authorised representative on behalf of the company appeared and attended the hearing.
C. Based on the facts and circumstances of the case, it is observed that the Company has violated the provision of section 92, liable to penalty under section 450 of the companies Act 2013 by making non-compliance in the Financial Year 2021-22 as in the meeting dated 31.03.2022 held for taking note of the resignation of Mr. Shirish Agarwal has been left to be incorporated in segment VIII. ?Meetings of Members/Class of Members/Board/Committees of the Board of Directors? and in sub-segment B ?Board Meetings? the e-form MGT-7A and consequently the attendance of the directors in the Sub segment C ?Attendance of Directors? has also been wrongly mentioned. Further wrong list of shareholding has also been attached in the said e-form. Thus, the Company and its every Officer who is in Default shall be liable under the provisions of Section 450 of the Act.
D. The period of default is considered from the date on which Form MGT-7A has been filed with ROC or Date of receipt of Form MGT-7A for the FY 2021-22, that is 19.10.2022. Accordingly, the company and every officer of the company who is in default or such other person shall be 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.
E. However, the Subject Company falls within the definition of a Small Company under the provisions of Section 2(85) of the Act as its paid-up capital is Rs. 1,00,000/- and its turnover is Rs. 106,582,724/- for the F.Y.2021-22. Therefore, as per the provisions of Section 446B of the Companies Act, 2013, the Company and the Officers in default shall be subject to penalty which shall not be more than one half of the prescribed penalty, that is Rs. 1,00,000/- (One Lakh Only) for company and Rs. 25,000/- (Twenty-Five Thousand) for officers in default in the instant case.
F. Now, in exercise of the powers conferred on the Adjudicating Officer vide Notification dated 24th March 2015, I hereby impose penalty of Rs. 1,00,000/- (One Lakh Only) on the Company and Rs. 25,000/- (Twenty-Five Thousand Only) on its Officers in default under Section 446B of the Act.
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 | SHREEKRISHNA IMPEX VENTURES LIMITED having CIN as U52190MP2020P LC050793 | 100000 | 0 | 200000 | |
| 2 | ASHISH AGARWAL having DIN as 08681765 |
25000 | 0 | 50000 | |
| 3 | RAKESH AGRAWAL having DIN as 09540525 |
25000 | 0 | 50000 | |
| 4 | SHIRISH RAMESH AGARWAL having DIN as 01832024 |
25000 | 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 Ahmedabad 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.
Anjali Pokhriyal,
Registrar of Companies
ROC Gwalior
