The Registrar of Companies (ROC), Kanpur, acting as the Adjudicating Officer under Section 454 of the Companies Act, 2013, has imposed a total penalty of ₹3,50,000/- on EAST ALPHA ALLIANCE TECHNOLOGY PRIVATE LIMITED and its three directors for non-compliance with statutory disclosure requirements. The order, dated October 14, 2025, addresses the company’s violation of Section 92(1)(g) of the Act, which pertains to accurately reporting particulars in the Annual Return (Form MGT-7). The default was initially identified during an inquiry conducted under Section 206(4) of the Act, which revealed a significant discrepancy in the company’s reporting for the financial year 2018-19.
The core finding of the Inquiry Officer was that the company’s financial statements reflected the payment of director remuneration amounting to ₹5,45,400/- and ₹3,50,000/-, yet the electronically filed Annual Return (MGT-7) for the same period stated that the remuneration paid to directors was ‘NIL’. This contradictory reporting constitutes a failure to comply with Section 92(1)(g). As there is no specific penalty prescribed under Section 92, the ROC invoked Section 450 of the Act, which provides a residual penalty for contraventions where no specific penalty is otherwise provided. The company and its directors were deemed officers in default. Despite being issued a Show Cause Notice on August 20, 2025, the company and the officers failed to submit any response or request a hearing, leading the Adjudicating Officer to proceed with imposing the penalty ex parte.
The penalties levied are ₹2,00,000/- on the company and ₹50,000/- each on the three directors—Sunny Kumar (DIN 07793089), Zhenghua Li (DIN 07793107), and Jianjun Lu (DIN 08385926)—totaling an initial ₹3,50,000/-. The order further requires the company and its officers to rectify the default and pay the penalty amount within 90 days of receiving the order. It was explicitly directed that the penalties imposed on the individual officers must be paid from their personal sources. Failure to comply with the payment timeline will lead to further penal consequences as outlined in Section 454(8) of the Act.
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/00768 Dated: 14/10/2025
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. 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 EAST ALPHA ALLIANCE TECHNOLOGY PRIVATE LIMITED [herein after known as Company] bearing CIN U74110UP2017PTC093229, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at F-304,GROUND FLOOR SECTOR-63 NA NOIDA GAUTAM BUDDHA NAGAR UTTAR PRADESH INDIA 201301
Individual details:
In the matter relating to SUNNY KUMAR [herein after known as individual] having DIN 07793089 and having its address at
In the matter relating to ZHENGHUA LI [herein after known as individual] having DIN 07793107 and having its address at
In the matter relating to JIANJUN LU [herein after known as individual] having DIN 08385926 and having its address at
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 Ministry vide letter No.F.No.3/211/2020-CL-II(NR) dated 28.10.2020 and subsequent letter No. ROC/Secret Reference/ Inquiry/4852 dated 05.08.2022 gave instructions to conduct the Inquiry U/s 206(4) of the Companies Act, 2013. The Inquiry Officer (IO) has observed from the financial statements for the year 2018-19 has paid remuneration to directors of Rs. 5,45,400 and 3,50,00. However, in the MGT-7 for the financial year 2018-19, Remuneration to directors is NIL. Hence the company has violated the provisions of section 92(1)(g) of the Companies Act, 2013. Hence the Inquiry Officer (IO) sought information and documents from the Company under Section 206(1) of the Companies Act, 2013. No reply furnished by the said director in respect of the said non-compliance. The report in this regard furnished to the Regional Director, Northern Region for the said non-compliance. The O/o DGCoA vide its letter.No.3/211/2020-CL-II(NR) dated 20.05.2024 has accorded the penal action under section 92 of the Companies
Act, 2013. Thus, it is evident that the Director has failed to comply with the provisions of section 92(1) (g) of the Companies Act, 2013 and are thus liable for penal provisions under section 450 of the Companies Act 2013 (as there is no specific provision of penalty for violation of section 92(1)(g). 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:
3. This office issued Show Cause Notice on 20.08.2025 to the company and its officer-in-default for violation of section 92(1)(g) of the Companies Act, 2013 as the financial statements for the year 2018-19, the company has paid remuneration to directors of Rs. 3,50,00. However, in the MGT-7 for the financial year 2018-19, Remuneration to directors is NIL. 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 as per Section 450 of the Companies Act, 2013.
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 as per Section 450 of the Companies Act, 2013.
4. 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 | EAST ALPHA ALLIANCE TECHNOLOGY PRIVATE LIMITED having CIN as U74110UP2017P TC093229 | 200000 | 0 | 200000 | |
| 2 | SUNNY KUMAR having DIN as
07793089 |
50000 | 0 | 50000 | |
| 3 | ZHENGHUA LI having DIN as
07793107 |
50000 | 0 | 50000 | |
| 4 | JIANJUN LU having DIN as08385926 |
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
