Regulatory Update: The Registrar of Companies, Mumbai II, issued Order ID PO/ADJ/07-2026/MR/02566 dated 23.07.2026 under Section 454 of the Companies Act, 2013 for adjudication of penalty against Harvindersingh Basantsingh Bindra, an officer of GNI Infrastructure Limited, for violation of Section 450 arising from non-compliance with Rule 8 of the Companies (Registration Offices and Fees) Rules, 2014. The company filed a suo motu adjudication application stating that, due to an inadvertent clerical/drafting oversight, the Cash Flow Statement was not attached to Form AOC-4 XBRL filed for FY 2020-21. The Registrar noted that Rule 8(3) makes the authorised signatory and certifying professional responsible for the correctness of the e-form and its enclosures, and directed the submission of the Cash Flow Statement for FY 2020-21. The noticee accepted the default, did not seek a personal hearing, and requested adjudication based on the written submissions. The Registrar imposed a penalty of ₹10,000 on Harvindersingh Basantsingh Bindra, directed rectification of the default and payment within 90 days, and provided for an appeal to the Regional Director, Navi Mumbai, within 60 days.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Mumbai II
100, Everest, Marine Drive, Mumbai, Maharashtra, India, 400002
Phone: 022-22812627
E-mail: roc.navimumbai@mca.gov.in
Order ID: PO/ADJ/07-2026/MR/02566 | Dated: 23/07/2026
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. 698(E) dated 10/02/2026 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 GNI INFRASTRUCTURE LIMITED [herein after known as Company] bearing CIN U42101MH2007PLC173342, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at C/O GN HOUSE, 3RD FLOOR, GUT NO. 107, PLOT NO. 07, RENUKA MATA KAMAN, SATARA PA, AURANGABAD SATARA PARISAR AURANGABAD AURANGABAD MAHARASHTRA INDIA 431010
Individual details:
In the matter relating to HARVINDERSINGH BASANTSINGH BINDRA ____________
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 – Whereas Registrar of Companies Mumbai-II (hereafter referred to as the ROC) is in receipt of a suo-moto Adjudication application dated SRN AC4251936 dated 28.06.2026 filed by the Company (hereafter referred to as the Applicant) under Section 454 of the Companies Act, 2013 (hereinafter referred to as the Act) for default under Rule 8 of the Companies (The Registration Offices and Fees) Rules, 2014 in respect to incorrect filing of AOC-4 XBRL filed vide SRN T89230460 for FY 2020-21.
Rule 8 of the Companies (The Registration Offices and Fees) Rules, 2014 reads as:
(1) An electronic form shall be authenticated by authorised signatories using digital signature and
(2) Rule 8 (3) reads as the authorised 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.
The applicant in adjudication application has stated due to an inadvertent clerical/drafting oversight, the Cash Flow Statement was not attached to the form. As per Rule 8(3) of the Companies (The Registration Offices and Fees) Rules, 2014, the authorised signatory and the professional who certifies the form shall be responsible for correctness of contents of e-form and correctness of enclosures attached with the e-form. Section 450 of the Companies Act, 2013 provides punishment for the contravention where no specific punishment is provided. Thus, Harindersingh Basantsingh Bindra is liable for penalty under section 450 of the Companies Act, 2013 as officers in default.
Further, you are directed to provide a copy of Cash Flow Statement for the financial year 2020-21
2. The noticee in his reply to show cause notice has submitted that it does not wish to avail the opportunity of personal hearing and requests that the matter may be adjudicated based on the submissions made herein. Hence, no E-hearing is scheduled and order is passed ex-parte.
E. Order:
1. i. The noticee in her reply to show cause notice has submitted that “it accepts the default as mentioned in the suo-moto adjudication application. The omission of the Cash Flow Statement in Form AOC-4 XBRL for FY 2020-21 occurred due to an inadvertent clerical/drafting oversight during compilation of the filing documents.”
ii. Companies (Registration Offices and Fees) Rules, 2014, states that the authorised signatory and the professional who certifies the form shall be responsible for correctness of contents of e-form and correctness of enclosures attached with the e-form. thus, HARVINDERSINGH BASANTSINGH BINDRA having DIN as 01553752, is liable for penalty under section 450 of the Companies Act, 2013.
iii. In view of facts of case and reply submitted by the applicant, a penalty of Rupees ten thousand (Rs.10000/-) is being imposed on HARVINDERSINGH BASANTSINGH BINDRA having DIN as 01553752.
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 | HARVINDERSINGH BASANTSINGH BINDRA having DIN as 01553752 | 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.
Anannya Saikia,
Registrar of Companies
ROC Mumbai II
