Penalty under Section 12(8) for Not Displaying Registered Office Details at Warehouses: ROC Ahmedabad Order

The Registrar of Companies, Ahmedabad has issued an adjudication order under Section 454 of the Companies Act, 2013 against VAHH CHEMICALS LIMITED for violation of Section 12(8) read with Section 12(3)(a). The default pertained to the company’s failure to display its name and registered office address at its warehouse locations for a specific period, leading to monetary penalties on the company and specified officers.

This order is a significant reminder that even what may appear to be a procedural requirement—such as affixing the company’s name and registered office address at business premises—is strictly enforceable and attracts penal consequences if ignored.

Statutory Requirement to Display Registered Office Details

Section 12(3)(a) of the Companies Act, 2013 mandates that:

  • Every company must paint or affix its name and the address of its registered office
  • On the outside of every office or place where it carries on business
  • In a conspicuous position and in legible letters

Warehouses, godowns, branches and any other business locations are treated as such “places of business” and are therefore covered by this mandate.

Penal Provision under Section 12(8)

The operative penal clause, as cited in the order, provides that:

If any default is made in complying with the requirements of this section, the company and every officer who is in default shall be liable to a penalty of one thousand rupees for every day during which the default continues but not exceeding one lakh rupees.

Thus:

  • Penalty is continuing in nature (per day of default)
  • However, there is an upper cap of ₹1,00,000 per person (company and each officer in default)

Appointment of Adjudicating Officer

The adjudicating authority acted pursuant to the powers conferred under Section 454 of the Companies Act, 2013.

  • The Ministry of Corporate Affairs, through Gazette Notification No. S.O. 698(E) dated 10/02/2026, appointed the undersigned Registrar of Companies, Ahmedabad, as the Adjudicating Officer.
  • The appointment is under Section 454 read with the Companies (Adjudication of Penalties) Rules, 2014.
  • The Adjudicating Officer is empowered to determine and impose penalties in respect of violations of the Act, including contraventions of Section 12.

Company and Officers Involved

Company Details

The proceedings relate to:

  • Company Name: VAHH CHEMICALS LIMITED
  • CIN: U24110GJ2019PLC111346
  • Registered Office Address:
    PLOT 2/5198 ETC, 5TH FLOOR, 5003, WORLD TRADE CENTRE,
    NEAR UDHNA DARAWAJA, RING ROAD NA,
    SURAT, SURAT, GUJARAT, INDIA, 395002

Individuals Connected with the Matter

The order references adjudication in relation to the following individuals:

  • GHANSHYAM MOHTA
  • AMAR ASHOKKUMAR JARIWALA
  • SAHIL BHAVESHKUMAR MODI
  • SHIVANI PARTH KOTHARI
  • PARAM VIPULKUMAR DESAI
  • HIREN INDRAVADAN DESAI
  • HETAL HIRENBHAI DESAI
  • AAYUSH HIREN DESAI
  • DHAIRYA BHARAT TULSIANI
  • JIGAR VYAS

Their respective DINs/PANs and roles are reflected in the penalty table forming part of the order.

Origin of Proceedings: Suo Motu Adjudication Application

Filing of GNL-1

The matter commenced with a suo motu adjudication application filed by the company:

  • Form GNL-1 filed vide SRN AC1907845 on 30.01.2026
  • Filed by M/s. Vahh Chemicals Limited along with Hiren Indravadan Desai, Managing Director

In this application, the company made a voluntary disclosure of non-compliance and sought adjudication under Section 454.

Factual Admission by the Company

In the narrative accompanying the GNL-1 application, the company admitted the following key facts: