The Registrar of Companies, Pune, issued an order dated 25.06.2026 under Section 454 of the Companies Act, 2013 for adjudication of penalty for violation of Section 10A(2) by MARCO SECURE SOLUTIONS LIMITED and its officers. The company submitted a suo motu application stating that it had commenced business on 04.06.2019 by entering into a loan agreement before filing the declaration for commencement of business, while Form INC-20A was filed on 20.01.2021. The noticees accepted the default and stated that it was identified during an internal compliance review, that corrective measures had been taken, and that the company was a Small Company and a DPIIT-recognized Startup eligible for the benefit of Section 446B. Upon considering the reply, the Adjudicating Officer observed that the company was recognized as a startup by DPIIT, held that Section 446B was applicable, noted that no public interest was involved, and imposed penalties of ₹25,000 on the company, ₹50,000 on Amol Gajanan Nale, and ₹50,000 on Chandasudha Goswami. The order directs payment and rectification within 90 days and specifies the appeal procedure under Section 454.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Pune
PCNTDA Green Building, BLOCK A, 1st & 2nd Floor , Near Akurdi Railway Station, Akurdi, Pune, Maharashtra, India,
411044
Phone: 020-27651375,020-27651378
E-mail: roc.pune@mca.gov.in
Order ID: PO/ADJ/06-2026/PU/02428 | Dated: 25/06/2026
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (THE ACT’) FOR VIOLATION OF SECTION 10A(2) 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 MARCO SECURE SOLUTIONS LIMITED [herein after known as Company] bearing CIN U71100PN2019PLC184570, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at FULLORA, FLOOR NO. 2 & 3, SURVEY NO. 28/2, CTS NO. 458 B/15, TEJAS COOPERATIVE HOUSING SOCIETY, PAUD ROAD KOTHRUD PUNE CITY PUNE MAHARASHTRA INDIA 411038
Individual details:
In the matter relating to AMOL GAJANAN NALE
In the matter relating to CHANDASUDHA GOSWAMI
C. Provisions of the Act:
If any default is made in complying with the requirements of this section, the company shall be liable to a penalty of fifty thousand rupees and every officer who is in default shall be liable to a penalty of one thousand rupees for each day during which such default continues but not exceeding an amount of one lakh rupees
D. Facts about the case:
1. Default committed by the officers in default/noticee – The company has submitted a suo-moto application dated 22.05.2026 u/s 454 of the companies Act, 2013 for adjudication of default u/s 10A of companies Act, 2013. It is observed from the application that the company has commenced the business on 04.06.2019 by entering into loan agreement before the filing the declaration for commencement of business. The company has filed form INC-20A on 20.01.2021. Hence the company and its officer who is in default violated the provisions of section 10A of companies Act, 2013 for which they are liable for action under section 10A (2) of Companies Act, 2013.
Accordingly, you are hereby called upon to show cause as to why penal action under Section 10A (2) of the Company Act, 2013 should not be initiated for the alleged violation of the provisions of the section 10A of the Companies Act, 2013 and you may submit objections/ reply, if any
2. The company and the officers in default have not requested for e-hearing and the Adjudicating Officer is also of the view that the e-hearing is not required in the instant case.
E. Order:
1. a. The company has filed a suo moto application for adjudication of offense under Section 454 of the Companies Act, 2013 for violation of 10A of the Companies Act 2013. Accordingly, a Show Cause notice bearing ID: SCN/ADJ/06-2026/PU/04794 dated 18.06.2026 was issued to the company and Officer in default (hereinafter referred to as the Noticee) under Section 454 of the Act. A reply of the noticees, to the said Show Cause Notice, was received vide letter dated 19.06.2026.
b. The noticees, in the reply, has accepted the default and further submitted that the Company had voluntarily conducted an internal compliance review and identified certain procedural non- compliances under the Companies Act, 2013. Immediately upon identification of the said lapses, the Company suo-moto approached the Honble Registrar of Companies by filing applications under Section 454 of the Companies Act, 2013 seeking adjudication. The defaults were neither intentional nor mala fide in nature. There was no wrongful gain to the Company, its directors, shareholders or any other person and no loss has been caused to any stakeholder. It is further submitted in the reply that the Company has already undertaken corrective measures and rectified all the concerned compliances. The company has also submitted that the company has, since its incorporation, continuously remained within the prescribed limits applicable to a Small Company under Section 2(85) of the Companies Act, 2013. Further the Company is a DPIIT-recognized Startup under the Startup India Initiative bearing Recognition Certificate No. DI PP180015, which is valid up to 03.06.2029. Accordingly, the Company qualifies as a ?Start-up Company? for the purposes of Section 4468 of the Companies Act, 2013 and is entitled to the benefit of lesser penalties prescribed thereunder.
c. On perusal of the replies by the company and the officers in default, it is observed that the company was duly recognized as a start-up by the Department of Promotion of Industry and Internal Trade (DPI IT). Thus, provision of Section 4468 of the Act is applicable in the instant case. Further, the company has accepted the default and it is seen that no public interest is involved in the matter.
d. Now, in exercise of the powers conferred on the undersigned vide Notification dated 24th March 2015 and having considered the replies submitted in response to the notice issued, I hereby impose the penalty on the noticee for violation of 10A of the Companies Act 2013 punishable under section Section 10A (2) of the Companies Act, 2013 as under.
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 | MARCO SECURE SOLUTIONS LIMITED having CIN as U71100PN2019P LC184570 | 25000 | 0 | 50000 | |
| 2 | AMOL GAJANAN NALE having DIN as 08471882 | 50000 | 0 | 100000 | |
| 3 | CHANDASUDHA GOSWAMI having DIN as 08471923 |
50000 | 0 | 100000 |
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.
Parvez Naikwadi,
Registrar of Companies
ROC Pune
