ROC Mumbai Imposes ₹10,000 Penalty for Incorrect AOC-4 Filing — Consolidated Financial Statements Not Attached
Overview of the Adjudication Order
The Registrar of Companies, Mumbai, functioning as an Adjudicating Officer under Section 454 of the Companies Act, 2013, has passed a penalty order against the Managing Director of Lorven International Limited for submitting incorrect particulars in E-form AOC-4 pertaining to Financial Year 2021–22. The error specifically involved the failure to attach consolidated financial statements, even though the company had a subsidiary, and the incorrect selection of "No" when the form asked whether such statements were required.
This order, bearing Order ID: PO/ADJ/04-2026/MH/02059, was issued on 24th April 2026 by Chandan Kumar, Registrar of Companies, ROC Mumbai I, located at 100, Everest, Marine Drive, Mumbai, Maharashtra — 400002.
Company and Individual Details
| Particulars | Details |
|---|---|
| Company Name | Lorven International Limited |
| CIN | U74999MH2006PLC165838 |
| Registered Office | Lorven House, Opp. Kaka Petrol Pump, Near Metro Mall, LBS Marg, Bhandup (West), Mumbai – 400078 |
| Officer in Default | Pankaj Baldevkumar Aggarwal |
| Designation | Chairman and Managing Director |
| DIN | 00744569 |
Legal Framework Governing the Default
Section 450 — Companies Act, 2013
The adjudication in this matter is premised on Section 450 of the Companies Act, 2013, which governs contraventions where no separate penalty or punishment has been specifically prescribed elsewhere in the Act. The relevant provision states:
"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 8(1) and Rule 8(3) — Companies (Registration Offices and Fees) Rules, 2014
The principal rules invoked in this matter are Rule 8(1) and Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014, which collectively establish the responsibility of signatories with respect to the accuracy of e-forms filed with the Ministry of Corporate Affairs (MCA).
Rule 8(1)mandates that every electronic form submitted to the Registrar must be authenticated by authorized signatories through the use of a valid digital signature.Rule 8(3)places direct and unequivocal responsibility on the authorized signatory — and any certifying professional — for the correctness of both the content of the e-form and all attachments filed along with it.
These provisions collectively establish that the individual affixing a digital signature to any e-form cannot disclaim responsibility for errors or omissions arising from that filing.