ROC Penalty on Company for Violation of Private Placement Rules:

ROC Penalty on Company for Violation of Private Placement Rules On 8th May, 2026, the Registrar of Companies, Pune, fined Innoctive Technologies Private Limited and its directors. The main question is after issuing 226 Compulsorily Convertible Preference Shares in a private placement approved on February 4, 2022, they filed their return of allotment Form PAS-3 46 days late. Legally, they should have filed that form by February 19. Instead, they got it done only on April 6, which set off penalties under Section 42(9) of the Companies Act, 2013. The company didn’t wait to be chased; they filed for adjudication on their own, which showed some good faith. They also asked for a single penalty, arguing that all the delays stemmed from a single process. The ROC, though, treated the PAS-3 delay as its own separate issue. Since Innoctive is registered as a startup with the DPIIT, Section 446B’s reduced penalties kicked in.  The company and its directors Vidyadhar Shinde, Raju Salve, and Deepesh Kuruppath now have to pay Rs 23,500, making a total of Rs 94,000, all due within 90 days.