The Registrar of Companies, Uttar Pradesh I, passed an adjudication order dated 10 July 2026 under section 454 of the Companies Act, 2013 against Panem Industries Private Limited and its officers for violation of section 134(8). A supplementary inspection under section 206(5) found that the company had not disclosed related party transactions for the financial year 2015-16 as required under section 134(5) read with Accounting Standard 18. Following a direction from the Office of the Director General of Corporate Affairs dated 10 December 2024, a show cause notice was issued on 8 May 2026. The company sought and was granted a hearing on 23 June 2026, during which an advocate appeared and assured that a reply would be filed; however, no reply was received thereafter. The Registrar held that the non-disclosure constituted a violation of Accounting Standard 18 read with section 134(5) and imposed a penalty of ₹3,00,000 on the company and ₹50,000 each on Praveen Nemani, Manoj Nemani, Rishi Katyal, Sharda Nemani, Vinay Kumar Dubey, Ena Katyal and Siddhartha Katyal. The order directs payment within 90 days and provides for an appeal before the Regional Director, Delhi, within 60 days.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Uttar Pradesh I
2nd Floor, Kendriya Bhawan, GPOA Building, Fazalganj, Kanpur, Uttar Pradesh, India, 208012
Phone: 0512-2310443
E-mail: roc.kanpur@mca.gov.in
Order ID: PO/ADJ/07-2026/UP/02529 Dated: 10/07/2026
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 134(8) 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 PANEM INDUSTRIES PRIVATE LIMITED [herein after known as Company] bearing CIN U27109UP1990PTC012439, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at PLOT NO 795 GUDHRAULI,CHAUDAGRA. NA FATEHPUR FATEHPUR UTTAR PRADESH INDIA 212665
Individual details:
In the matter relating to PRAVEEN NEMANI ——————
In the matter relating to MANOJ NEMANI —————
In the matter relating to RISHI KATYAL———————–
In the matter relating to SHARDA NEMANI ———————
In the matter relating to VINAY KUMAR DUBEY ———————-
In the matter relating to ENA KATYAL ——————–
In the matter relating to SIDDHARTHA KATYAL —————–
C. Provisions of the Act:
(8) If a company is in default in complying with the provisions of this section, the company shall be liable to a penalty of three lakh rupees and every officer of the company who is in default shall be liable to a penalty of fifty thousand rupees
D. Facts about the case:
1. Default committed by the officers in default/noticee – The Supplementary Inspection u/s 206 (5) of the Companies Act, 2013 has been carried out and the Inspector has submitted his report and pointed that the company has not disclosed the related party transactions as required under section 134(5) of the Companies Act, 2013 read with Accounting Standard 18 for the Financial Year 2015-16 and therefore, is liable for violation of Section 134(5) read with AS-18 of the Companies Act, 2013. The O/o DGCoA vide letter dated 10.12.2024 has been directed to take penal action for violation of Section 134(5) read with AS-18 of the Companies Act, 2013 and liable for penal action as per the provisions of section 134 (8) of the Companies Act, 2013.
Keeping in view of the above, you are hereby called upon to show cause as to why penal action should not be initiated against the company and its officers in default of the aforesaid default.
2. Hearing Granted
E. Order:
1. The company has not disclosed the related party transactions as per mandate of Accounting Standard 18 read with section 134(5) of the Companies Act, 2013 for the Financial Year 2015-16, which is in violation of Accounting Standard 18 read with Section 134(5) of the Companies Act, 2013 making the company and its officer in default liable for penalty as provided under section 134 (8) of the Companies Act, 2013.
This office issued Show Cause Notice on 08.05.2026 to the company and every officer of the Company who are in default. In response, Company requested for hearing which was duly provided on 23.06.2026 and an advocate appeared on behalf of the Company and assured for reply. Shri Ramesh Kumar Pal (AROC) was also present. However, no reply has been received till date. In the said circumstances, penalty as applicable as mentioned below are imposed as per section 134(8) of the Companies Act, 2013 on the Company and its officers in default for violation of Accounting Standard 18 read with Section 134(5) of the Companies Act, 2013 for the Financial Year 2015-16.
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 | PANEM INDUSTRIES PRIVATE LIMITED having CIN as U27109UP1990P TC012439 | 300000 | 0 | 300000 | |
| 2 | PRAVEEN NEMANI having DIN as 01111455 | 50000 | 0 | 50000 | |
| 3 | MANOJ NEMANI having DIN as 01842350 | 50000 | 0 | 50000 | |
| 4 | RISHI KATYAL having DIN as 02551147 | 50000 | 0 | 50000 | |
| 5 | SHARDA NEMANI having DIN as 03310557 | 50000 | 0 | 50000 | |
| 6 | VINAY KUMAR DUBEY having DIN as 08110909 | 50000 | 0 | 50000 | |
| 7 | ENA KATYAL having DIN as 06814006 | 50000 | 0 | 50000 | |
| 8 | SIDDHARTHA KATYAL having DIN as 01842531 | 50000 | 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.
Sanjay Bose,
Registrar of Companies
ROC Uttar Pradesh I
