The Registrar of Companies, Uttar Pradesh II, by Order ID PO/ADJ/07-2026/UW/02618 dated 31/07/2026, adjudicated penalty proceedings under Section 454 of the Companies Act, 2013 for violation of Section 450 in relation to non-compliance with Section 123(4) by J Pan Tubular Components Limited. The order records that the dividend approved by shareholders on 30.09.2022 for FY 2021-22 was required to be deposited in a separate bank account by 04.10.2022 but was deposited on 06.10.2022, resulting in a delay of two days. The company submitted that it had suo motu filed an adjudication application in Form GNL-1, attributed the delay to holidays during October 2022, and stated that it is a closely held company. After considering the reply, the Adjudicating Officer imposed a penalty of ₹10,000 each on the company and four officers in default—Manoj Kumar Verma, Jignesh Panchal, Navneet Bhardwaj, and Jubin Jignesh Panchal. The order directs rectification of the default and payment of the penalty within 90 days and provides for an appeal to 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/02618 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 MANOJ KUMAR VERMA________
In the matter relating to JIGNESH PANCHAL___________
In the matter relating to NAVNEET BHARDWAJ__________
In the matter relating to JUBIN JIGNESH 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 2021-22 shareholder approval for dividends was approved on 30.09.2022 and due date of dividend to be deposited was 04.10.2022 (within 5 days of declaration) which was actually deposited into a separate bank account on 06.10.2022 with a delay of 02 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 requested
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/04570 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- AC3068022 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 06.10.2022 with a delay of two days. The company has also submitted the said non-compliance was un-intentional and was occurred due to the Durssehra holiday during the month of October 2022. There was a national holiday on 2nd October 2022 (Mahatma Gandhi Jayanti) and 5th October 2022 was Dussehra. Further 3rd October and 4th October 2022 were restricted holidays were Durga Ashtami & Mahanavami. 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 | MANOJ KUMAR VERMA having DIN as 03025718 | 10000 | 0 | 50000 | |
| 3 | JIGNESH
PANCHAL having DIN as 02085715 |
10000 | 0 | 50000 | |
| 4 | NAVNEET BHARDWAJ having DIN as 09383702 |
10000 | 0 | 50000 | |
| 5 | JUBIN JIGNESH PANCHAL having DIN as 09383754 |
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
