ROC Mumbai Penalises Nominee Director Over Filing Error in AOC-4

The Registrar of Companies (ROC), Mumbai, has imposed a penalty on the director of Alps Remedies Pvt. Ltd. for reporting an incorrect date of the Annual General Meeting (AGM).

The Registrar of Companies, Mumbai, received a suo-motu adjudication application dated February 04, 2026, filed through Form GNL-1 by Mr Shankar Srinivasan, who is a Nominee Director of the company. The application was made under Section 454 of the Companies Act, 2013, because there was an error in filing Form AOC-4 for the financial year 2024-25.

As per Rule 8(1) and Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014, any electronic form must be signed using a digital signature by an authorised signatory, and both the signatory and the professional certifying the form are responsible for ensuring that the details and attachments in the form are correct.

The applicant explained that while filing Form AOC-4 on December 18, 2025, the company mistakenly mentioned the date of the Annual General Meeting (AGM) as September 30, 2025, instead of the actual date, which was September 15, 2025. Because of this incorrect date, the company is now unable to file Form MGT-7 with the correct AGM date. The form was digitally signed and declared by Mr Shankar Srinivasan.

Since the rules clearly state that the authorised signatory is responsible for the correctness of the information filed, Mr Shankar Srinivasan, being the Nominee Director and signatory, is liable for a penalty under Section 450 of the Companies Act, 2013. As a result, ROC imposed a penalty of Rs. 10,000 on the company’s nominee director.