The Registrar of Companies, Mumbai II, issued an adjudication order dated July 14, 2026 under Section 454 of the Companies Act, 2013 imposing a penalty under Section 450 for violation of Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014. The matter arose from a suo motu adjudication application dated May 8, 2026 relating to incorrect filing of Form AOC-4 for FY 2024–25. The company stated that, due to an inadvertent clerical and human error, the financial statements and Auditor’s Report of another company were attached instead of those of CADSGATE-ACE SOLUTIONS PRIVATE LIMITED. The noticee submitted that the error was accidental, there was no intention to conceal information or violate the Act, and requested a lenient view without seeking an e-hearing. The Adjudicating Officer observed that Rule 8(3) makes the authorised signatory responsible for the correctness of the contents and enclosures of the e-form, directed submission of the financial statements and Auditor’s Report for FY 2024–25, and imposed a penalty of ₹5,000 on the director. The noticee was directed to rectify the default, pay the penalty within 90 days, and may appeal before the Regional Director, Navi Mumbai, within 60 days.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Mumbai II
100, Everest, Marine Drive, Mumbai, Maharashtra, India, 400002
Phone: 022-22812627
E-mail: roc.navimumbai@mca.gov.in
Order ID: PO/ADJ/07-2026/MR/02532 Dated: 14/07/2026
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 CADSGATE-ACE SOLUTIONS PRIVATE LIMITED [herein after known as Company] bearing CIN U62011MH2024PTC428576, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at FLAT NO 301,AARADHYA TULIP,MANDLIK MALA MAKHMALABAD NASHIK NASHIK MAHARASHTRA INDIA 422003
Individual details:
In the matter relating to SHUBHANGI DHARMENDRA THUBE —————–
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 Registrar of Companies Mumbai-II (hereafter referred to as the ROC) is in receipt of a suo-moto Adjudication application dated SRN AC3381764 dated 08.05.2026 filed by the Company (hereafter referred to as the Applicant) under Section 454 of the Companies Act, 2013 (hereinafter referred to as the Act) for default under Rule 8 of the Companies (The Registration Offices and Fees) Rules, 2014 in respect to incorrect filing of AOC-4 filed vide SRN AC0624622 for FY 2024-25.
Rule 8 of the Companies (The Registration Offices and Fees) Rules, 2014 reads as:
(1)An electronic form shall be authenticated by authorised signatories using digital signature and
(2)Rule 8 (3) reads as the authorised signatory and the professional, if any, who certify e-form shall be responsible for the correctness of the contents of e-form and correctness of the enclosures attached with the electronic form.
The applicant in adjudication application has stated due to an inadvertent clerical and human error, the financial statements and Auditor’s Report of another company were attached instead of Cadsgate-Ace Solutions private Limited. As per Rule 8(3) of the Companies (The Registration Offices and Fees) Rules, 2014, the authorised signatory and the professional who certifies the form shall be responsible for correctness of contents of e-form and correctness of enclosures attached with the e-form. Section 450 of the Companies Act, 2013 provides punishment for the contravention where no specific punishment is provided. Thus, Subhangi Dharmendra Tubhe is liable for penalty under section 450 of the Companies Act, 2013 as officers in default.
Further, you are directed to provide a copy of financial statement and Auditor?s report for the financial year 2024-25.
2. The noticee in her reply to show cause notice has not asked for e-hearing and requested to take a lenient view while passing the order. Therefore, no e-hearing is scheduled and order is passed ex-parte.
E.Order:
1. i. The noticee in her reply to show cause notice has submitted that the default occurred due to an inadvertent clerical/human error while filing Form AOC4 for the Financial Year 2024-25. By mistake, the Financial Statements and Auditor’s Report of another company were attached instead of those of CADSGATE-ACE SOLUTIONS PRIVATE LIMITED. The error was purely accidental and there was no intention to conceal any information or violate the provisions of the Companies Act, 2013.
ii. Companies (Registration Offices and Fees) Rules, 2014, states that the authorised signatory and the professional who certifies the form shall be responsible for correctness of contents of e-form and correctness of enclosures attached with the e-form. thus, SHUBHANGI DHARMENDRA THUBE having DIN as 10701944, is liable for penalty under section 450 of the Companies Act, 2013.
iii. In view of facts of case and reply submitted by the applicant, a penalty of Rupees five thousand (Rs.5000/-) is being imposed on SHUBHANGI DHARMENDRA THUBE having DIN as 10701944.
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 | SHUBHANGI DHARMENDRA THUBE having DIN as 10701944 |
|
5000 | 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 Navi Mumbai 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.
Anannya Saikia,
Registrar of Companies
ROC Mumbai II
