ROC Cuttack Penalises GURUMAHARAJ ENGICON PRIVATE LIMITED for Delayed Filing of Form CSR-2 for FY 2020-21
Overview of the Adjudication Order
The Registrar of Companies, Cuttack has passed an adjudication order under Section 454 of the Companies Act, 2013 against GURUMAHARAJ ENGICON PRIVATE LIMITED (CIN: U45500OR2019PTC030866) and its officers for failing to file Form CSR-2 within the prescribed time limit for Financial Year 2020-21. The violation pertains to Rule 12(1B) of the Companies (Accounts) Rules, 2014, with penalties imposed under Section 450 of the Companies Act, 2013. The order bears reference Order ID: PO/ADJ/07-2026/CT/02523, dated 13th July 2026.
The company, which has its registered office at Plot No-698, GEPL House, Nayapalli, Bhubaneswar, Khordha, Odisha – 751012, was required to submit Form CSR-2 for FY 2020-21 on or before 30.06.2022 but eventually filed the same only on 03.06.2026 — a delay spanning nearly four years.
Appointment of the Adjudicating Officer
The Ministry of Corporate Affairs, through its Gazette Notification No. S.O. 698(E) dated 10/02/2026, appointed the undersigned as the Adjudicating Officer in exercise of powers granted under Section 454 of the Companies Act, 2013, read with the Companies (Adjudication of Penalties) Rules, 2014. The appointment authorises the officer to adjudge and impose penalties for contraventions under the Act.
Legal Framework: Relevant Provisions
Section 450 — Companies Act, 2013
The penal provision invoked in this matter is Section 450 of the Companies Act, 2013, which applies to contraventions for which no separate penalty is prescribed elsewhere in the Act. The provision reads as follows:
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 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.
Rule 12(1B) — Companies (Accounts) Rules, 2014
The filing obligation at the centre of this dispute arises from Rule 12(1B) of the Companies (Accounts) Rules, 2014, which mandates that:
Every Company covered under the provisions of sub-section (1) to section 135 shall furnish a report on Corporate Social Responsibility in Form CSR-2 to the Registrar for the preceding financial year (2020-21) and onwards as an addendum to Form AOC-4 or AOC-4 XBRL or AOC-4 NBFC (Ind. AS), as the case may be. Provided that for the preceding financial year (2020-21), Form CSR-2 shall be filed separately on or before 30.06.2022, after filing Form AOC-4 or AOC-4 XBRL or AOC-4 NBFC (Ind. AS), as the case may be.
This provision placed a clear obligation on the assessee-company to file Form CSR-2 for FY 2020-21 separately and before 30.06.2022, which the company failed to comply with.