The Registrar of Companies, Uttar Pradesh II, issued an adjudication order dated 31.07.2026 under Section 454 of the Companies Act, 2013 for violation of Section 123(4) read with Section 450 by J PAN TUBULAR COMPONENTS LIMITED and its directors. The order records that the dividend approved by shareholders on 29.09.2021 for FY 2020-21 was required to be deposited into a separate bank account by 03.10.2021 but was actually deposited on 22.10.2021, resulting in a delay of 19 days. The company, through its reply, stated that it had suo motu filed an adjudication application in Form GNL-1, that the delay was unintentional and occurred due to the COVID pandemic and restrictions in force until October 2021, and that it was a closely held company. After considering the reply, the Adjudicating Officer imposed penalties of Rs. 10,000 each on the company and its directors, Jignesh Panchal and Bhavesh Panchal. The noticees were directed to rectify the default and pay the penalties within 90 days, with a right to appeal before the Regional Director, Delhi within 60 days.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Uttar Pradesh II
2nd Floor, Kendriya Bhawan, GPOA Building, Fazalganj, Kanpur, Uttar Pradesh, India, 208012
Phone: 0512-2310443
E-mail: roc.noida@mca.gov.in
Order ID: PO/ADJ/07-2026/UW/02619 | Dated: 31/07/2026
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 J PAN TUBULAR COMPONENTS LIMITED [herein after known as Company] bearing CIN U29253UP2007PLC169950, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at B-2/31,32 & 42, SITE-B SURAJPUR INDUSTRIAL AREA NA GREATER NOIDA GAUTAM BUDDHA NAGAR UTTAR PRADESH INDIA 201306
Individual details:
In the matter relating to JIGNESH PANCHAL ——
In the matter relating to BHAVESH PANCHAL ——
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 –
That as per section 123(4) of the Companies Act, 2013 which mandates that the amount of dividend, including interim dividend, shall be deposited in a separate bank account within five days form the date of declaration.
That in the financial year 2020-21 shareholder approval for dividends was approved on 29.09.2021 and due date of dividend to be deposited was 03.10.2021 (within 5 days of declaration) which was actually deposited into a separate bank account on 22.10.2021 with a delay of 19 days.
Hence, the company and its then directors were failed to comply with the provisions of section 123(4) of the Companies Act, 2013 and are liable for the penal provision under section 450 the Companies Act, 2013 (as there is no specific penalty provision for the non-compliance).
2. e-hearing not desired
E. Order:
1. The company through its director Shri Jignesh Panchal has furnished a reply dated 03.06.2026 to the Show Cause Notice SCN/ADJ/05-2026/UW/04573 dated 26.05.2026. It is pertinent to mention here that the company in its reply has submitted that the company and its directors have Suo-moto filed an adjudication application in Form GNL-1 vide SRN- AC3068202 to adjudicate the default for the violation of section 123(4) of the Companies Act, 2013 for the financial year 2021-22. The company in its reply also submitted that the company has deposited the dividend amount into a sperate bank account on 22.10.2021 with a delay of 19 days. The company has also submitted the said non-compliance was un-intentional and had occurred due to the Pandemic ?COVID? and the restrictions which were in-forced strictly till October 2021. The company has also submitted that since incorporation Mr. Jignesh Panchal, Director of the company is holding more than 90% of the shares of the company and is closely held company.
In view of above considering facts submitted by the company the details of penalty imposed on the company, officers in default and others are shown in the table below:
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 | J PAN TUBULAR COMPONENTS LIMITED having CIN as U29253UP2007P LC169950 | 10000 | 0 | 200000 | |
| 2 | JIGNESH
PANCHAL having DIN as 02085715 |
10000 | 0 | 50000 | |
| 3 | BHAVESH PANCHAL having DIN as 02127765 | 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 Delhi 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.
Vineet Rai,
Registrar of Companies
ROC Uttar Pradesh II
