ROC Levies Penalty for not Affixing CIN Number on Company Letterhead

In a recent enforcement action, the Registrar of Companies (ROC) of NCT of Delhi and Haryana has penalized Shivnath Holdings Private Limited and its directors for not mentioning the Corporate Identity Number (CIN) on official publications, an offense under Section 12(3)(c) of the Companies Act, 2013.

The judgment order dated April 16, 2025, explains the manner in which regulatory agencies are strictly implementing corporate governance rules even in apparently minor crimes. During the investigation, it was revealed that the authority was violating the laws. It was found that it had missed placing its CIN number on a notice and board report dated August 27, 2014, submitted to the Ministry of Corporate Affairs.

Subsequent to the detection of the misconduct, the ROC sent a show cause notice to the firm as well as its directors in February 2023. Upon no initial reply, a follow-up notice was put out in May 2023, to which the firm replied in June 2023, owning up to the violation of ROC Levies Penalty for not Affixing CIN Number on Company Letterhead of the Companies Act.

In Section 12(3)(c), it is mandatory for companies to place their name, registered office address, Corporate Identity Number, telephone number, fax number (if any), email, and website addresses on all business letters, billheads, letter papers, notices, and official publications. This provision is meant to promote transparency and allow stakeholders to verify and identify company details with ease.

The Registrar, as Judicial Officer, calculated fines for each occasion that the company made use of wrong letterheads. Since Shivnath Holdings was a small firm under Section 2(85) of the Companies Act, the fine was halved to half of what was stipulated.

The Registrar, acting as Adjudicating Officer, measured penalties for every instance that the company used the incorrect letterhead. As Shivnath Holdings was a small company under Section 2(85) of the Companies Act, the penalty was cut to half of the stipulated amount. The company and each of its two directors—Isha Garg and Mahesh Chander—were ordered to pay Rs. 2,000 each.

The order directs payment within 90 days through the MCA website and immediate rectification of the default. The company and its directors have the right to appeal to the Regional Director within 60 days of receiving the order.

This is a reminder to all companies of the importance of remaining in step with even the more mundane technical requirements of the Companies Act. Failure to make proper inclusion in official communication of information that should be included may result in not only penalties against the company itself but also its individual directors, highlighting the dimension of personal liability of corporate governance crimes.