ROC Chennai Imposes Penalty for Delay in Filing Return of Allotment PAS-3

The Registrar of Companies (ROC), Chennai, imposed a penalty on Sweet Karam Coffee India Private Limited and its officers in default for the delay in filing the Return of Allotment in Form PAS-3.

The company M/s Sweet Karam Coffee India Private Limited and its directors filed Form GNL-1 and also submitted a physical application for suo motu adjudication under Section 454 of the Companies Act, 2013.

The company allotted 300 non-convertible debentures (NCDs) to Stride Ventures Debt Fund 3 on September 13, 2024. However, the company filed e-Form PAS-3 on November 14, 2024, which was 46 days late beyond the allowed 15-day period.

ROC stated that the company violated Section 42(8) because of this delay. The Adjudicating Authority also issued a Show Cause Notice on December 31, 2025, for the violation.

However, the company replied that the delay happened by mistake and without any intention to violate the law. The company also requested the authority to take a lenient view and impose a lesser penalty.

During the e-hearing, Mr Ayush Agarwal, authorised representative of Mr Vettakkorumakankav Subramaniam Sitaram, stated that Mr Sitaram was not a director of the company at the time when the default occurred. Therefore, it was argued that he should not be held liable for the penalty in this case.

The company also submitted e-Form GNL-3 by email to designate certain individuals as Officers in Default. As a result, ROC imposed a penalty of Rs 46,000 on the company and Rs 46,000 each on its officers in default.