The Registrar of Companies (ROC), Kanpur, issued an Adjudication Order (dated 14/10/2025) under the Companies Act, 2013, imposing penalties on three directors of EAST ALPHA ALLIANCE TECHNOLOGY PRIVATE LIMITED. The order addresses a violation of Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014, which mandates the annual filing of the Director Identification Number (DIN) Know Your Customer (KYC) form (DIR-3 KYC). An inquiry found that the DINs belonging to all three directors—Zhenghua Li, Lun Tian, and Sunny Kumar—were deactivated due to this persistent non-filing. This failure to comply with a crucial administrative requirement led to the imposition of penalties under Section 450 of the Act, which covers offenses for which no specific penalty is provided elsewhere. The directors failed to furnish a reply or documents to the Inquiry Officer concerning this default.
The formal adjudication process was initiated by the ROC with the issuance of a Show Cause Notice on June 24, 2025. The order explicitly states that the three directors, being the officers in default, failed to provide any response to the notice or submit any request for a formal hearing, even after the expiration of the stipulated time. Given the confirmed non-compliance and the lack of engagement from the noticees, the Adjudicating Officer proceeded with the imposition of penalties as prescribed under Section 450. A penalty of ₹50,000 was levied upon each of the three individual directors: Zhenghua Li, Lun Tian, and Sunny Kumar. The cumulative penalty imposed on the directors for this non-filing of the DIN KYC form totaled ₹1,50,000.
The ROC order mandates that the penalized directors must rectify the default by ensuring the proper filing of their DIR-3 KYC forms to reactivate their DINs. Additionally, they are required to pay their respective penalty amounts within 90 days of receiving the official order. The penalties imposed upon the individuals must be paid from their personal sources/income via the Ministry of Corporate Affairs’ ‘e-Adjudication’ facility. The order also notifies the noticees of their right to file an appeal against the decision with the Regional Director, RD Noida, within a period of sixty days from the date of receipt, utilizing Form ADJ. Failure to pay the penalty within the prescribed time limit will result in further penal consequences as outlined in Section 454(8) of the Companies Act, 2013.
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/00765 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 ZHENGHUA LI [herein after known as individual] having DIN 07793107 and having its address at
In the matter relating to LUN TIAN [herein after known as individual] having DIN 08672416 and having its address at
In the matter relating to SUNNY KUMAR [herein after known as individual] having DIN 07793089 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. During the course of inquiry, It has been observed from the that KYC status of all the directors of the Company namely Mr. Sunny Kumar, Zhenghua LI and Mr. Lun Tian are deactivated due to non-filing of DIR-3 KYC. Hence, it is violation of Rule 12A of Companies (Appointment and Qualification of Directors) Rules, 2014. 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 . F.No. 3/211/2020-CL-II-(NR)-DGCoA-MCA dated 20.05.2024 has accorded with the penal action under Rule 12 A of the
Companies Act, 2013. Thus, it is evident that the Directors have failed to comply with the provisions of Rule12A of the Companies Act, 2013 and are thus liable for penal provisions under section 450 of the Companies Act, 2013.
2. Neither any response has been received from Mr. Sunny Kumar, Mr. Zhenghua LI and Mr. Lun Tian nor any request of hearing received in this regard.
E. Order:
1. This office issued Show Cause Notice on 24.06.2025 to Mr. Sunny Kumar, Mr. Zhenghua LI and Mr. Lun Tian as the DINs of Mr. Sunny Kumar, Mr. Zhenghua LI and Mr. Lun Tian are deactivated due to non-filing of DIR-3 KYC which is non-compliance of Rule 12A of Companies (Appointment and Qualification of Directors) Rules, 2014.
More than 15 days have expired from issue of Show Cause Notice, no response has been received till date. Mr. Sunny Kumar, Mr. Zhenghua LI and Mr. Lun Tian 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.
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 | ZHENGHUA LI having DIN as
07793107 |
50000 | 0 | 50000 | |
| 2 | LUN TIAN having DIN as 08672416 | 50000 | 0 | 50000 | |
| 3 | SUNNY KUMAR having DIN as
07793089 |
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].
5. 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
