ROC Cuttack Imposes Penalty on Malook Chand Foods Pvt. Ltd. for Late Filing of Form CSR-2 for FY 2020-21

Overview of the Adjudication Order

The Registrar of Companies, Cuttack, exercising adjudicatory powers under Section 454 of the Companies Act, 2013, issued an adjudication order bearing Order ID PO/ADJ/07-2026/CT/02583 dated 27th July 2026 against Malook Chand Foods Private Limited (CIN: U15143OR2002PTC006688). The proceedings were initiated for contravention of Rule 12(1B) of the Companies (Accounts) Rules, 2014, read with Section 450 of the Companies Act, 2013, on account of significant delay in filing Form CSR-2 for the financial year 2020-21.

The total penalty levied across the company and its officers in default amounts to ₹3,50,000, with ₹2,00,000 imposed on the company and ₹50,000 each on three identified directors/officers.

Background: Appointment of the Adjudicating Officer

The Ministry of Corporate Affairs, through Gazette Notification No. S.O. 698(E) dated 10/02/2026, designated the Registrar of Companies, Cuttack, as the Adjudicating Officer under Section 454 of the Companies Act, 2013, read with the Companies (Adjudication of Penalties) Rules, 2014. This appointment confers the authority to adjudge penalties for violations enumerated under the Act.

Company and Officers Involved

  • Company: Malook Chand Foods Private Limited
  • CIN: U15143OR2002PTC006688
  • Registered Office: S-3A/66, Mancheswar Industrial Estate, Bhubaneshwar, Odisha – 751001
  • Officers in Default:
    • Dinesh Chand Agarwal (DIN: 00783263)
    • Praveen Kumar (DIN: 00783274)
    • Krati Agarwal (DIN: 08529083)

Section 450 of the Companies Act, 2013

Section 450 governs contraventions for which no specific penalty is prescribed elsewhere in the Act. The relevant 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) of the Companies (Accounts) Rules, 2014

Rule 12(1B) mandates that every company falling within the ambit of Section 135(1) of the Companies Act, 2013 — that is, every company obligated to constitute a Corporate Social Responsibility Committee — must submit its CSR report in Form CSR-2 to the Registrar for the preceding financial year and beyond, as an addendum to Form AOC-4, AOC-4 XBRL, or AOC-4 NBFC (Ind. AS), as applicable.