The Registrar of Companies (ROC), Kanpur, acting as the Adjudicating Officer, has imposed a total penalty of ₹4,00,000/- on ALL TIME ACTIVATION SOFTWARE SOLUTION PRIVATE LIMITED and its two directors for violating Section 134 of the Companies Act, 2013. The order, dated October 15, 2025, addresses the company’s failure to file the Director’s Report for the financial year ended March 31, 2020. The default was initially identified during an inspection conducted under Section 206(5) of the Act, which confirmed the complete non-filing of the statutory report. This non-compliance directly attracts the penal provisions outlined in Section 134(8) of the Act, which specifies penalties of ₹3,00,000/- for the company and ₹50,000/- for every officer in default.
The ROC issued a Show Cause Notice to the company and its two directors, Shailendra Kumar Singh (DIN 07399422) and Subhashita (DIN 07954590), on August 20, 2025. As no response was received from the company or its officers-in-default, and no request for a hearing was made, the Adjudicating Officer proceeded to impose the maximum prescribed penalties ex parte. Consequently, a penalty of ₹3,00,000/- was levied on the company, and ₹50,000/- was levied on each of the two directors, resulting in a total imposed penalty of ₹4,00,000/-. The order mandates that the company and its officers must rectify the default and remit the penalty amount within 90 days of receiving the order, with the directors explicitly required to pay from their personal sources. Failure to comply is subject to further penal consequences under Section 454(8).
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Kanpur
Registrar of Companies, 37/17, Westcottt Buidling, The Mall, Kanpur, Uttar Pradesh, India, 208001
Phone: 0512-2310443,2310227,2310323
E-mail: roc.kanpur@mca.gov.in
Order ID: PO/ADJ/10-2025/KN/00782 Dated: 15/10/2025
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. 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 ALL TIME ACTIVATION SOFTWARE SOLUTION PRIVATE LIMITED [herein after known as Company] bearing CIN U72200UP2017PTC093832, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at 11 EAST SABIT GANJ ETAWAH NA ETAWAH ETAWA UTTAR PRADESH INDIA 206001
Individual details:
In the matter relating to SHAILENDRA KUMAR SINGH [herein after known as individual] having DIN 07399422 and having its address at
In the matter relating to SUBHASHITA . [herein after known as individual] having DIN 07954590 and having its address at
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 – Whereas Ministry vide letter No.F.No.3/487/2018-CL-II(NR) dated 07.07.2020 gave instructions to conduct the Inspection U/s 206(5) of the Companies Act, 2013. The Inspecting Officer (IO) has observed that the Company has not filed director reports for the financial year ended 31.03.2020 . Accordingly, the Inspecting officer has reported the said violation in the Inspection Report dated 19.07.2022. The O/o DGCoA vide letter CL-II-01/161/2023-O/o DGCoA-MCA dated 29.10.2024 has accorded the penal action for said non-compliance. Thus, it is evident that the company and its Directors have failed to comply with the provisions of section 134 of the Companies Act, 2013, in filing of the director report, thereby attracting the penal provisions mentioned under Section 134(8) of the Act. The Company and its Directors are officers in default, as per section 2(60), of the Companies Act, 2013. And are thus liable for penal provisions.
2. Neither any response has been received from the company and its officer-in-default nor any request of hearing received in this regard.
E. Order:
1. This office issued Show Cause Notice on 20.08.2025 to the company and its officer-in-default as the company and its Directors have failed to comply with the provisions of section 134 of the Companies Act, 2013, in filing of the director report for the Financial Year ended as at 31.03.2020, thereby attracting the penal provisions mentioned under Section 134(8) of the Act.
More than 15 days have expired from issue of Show Cause Notice, no response has been received till date. The company and its officer-in default have also not requested for hearing. In the said circumstances, penalty as applicable as mentioned below is being imposed upon the company as well as its officer-in default as per Section 134 (8) of the Companies Act, 2013.
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 | ALL TIME ACTIVATION SOFTWARE SOLUTION PRIVATE LIMITED having CIN as U72200UP2017P TC093832 | 300000 | 0 | 300000 | |
| 2 | SHAILENDRA KUMAR SINGH having DIN as 07399422 | 50000 | 0 | 50000 | |
| 3 | SUBHASHITA . having DIN as
07954590 |
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 Noida 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 Kanpur
