The Registrar of Companies (ROC), Pune has passed three separate adjudication orders, all dated 23 January 2026, imposing penalties on Arcatron Mobility Private Limited and one of its directors for non-compliance with the provisions of the Companies Act, 2013.
Each order was issued under Section 454 of the Act for violations punishable under Section 450, pursuant to independent suo-moto applications filed by the company in respect of three different preferential allotment filings.
Company and Parties Involved
Company: Arcatron Mobility Private Limited (CIN: U29299PN2015PTC155291)
Adjudicating Authority: Registrar of Companies, Pune
Director Designated as Officer in Default: Ganesh Sharad Sonawane (Other directors were named in the proceedings; however, no monetary penalty was imposed on them in any of the orders)
The company is registered in Pune, Maharashtra, and is recognised as a DPIIT-registered start-up and a small company under the Companies Act, 2013.
Nature of the Defaults
Across all three matters, the defaults arose from procedural non-compliance in preferential allotments of shares. The company failed to disclose certain mandatory particulars required under:
- Section 62(1)(c) of the Companies Act, 2013, read with
- Rule 13 of the Companies (Share Capital and Debentures) Rules, 2014
The omissions were found in documents attached to Form MGT-14, filed on three separate occasions in earlier years (2017–2018). Each filing related to a distinct preferential allotment and was therefore treated as an independent contravention.
The company submitted that the lapses were unintentional and purely procedural, without any fraudulent intent.
Voluntary Disclosure and Adjudication
For each default, the company and its directors voluntarily filed suo-moto applications seeking adjudication under Section 454 of the Act. After examining the replies, ROC Pune recorded that:
- Violations under Section 62(1)(c) read with Rule 13 were established in all three cases
- The company qualified for benefit of Section 446B, applicable to start-ups and small companies
- One director was designated as the Officer in Default
- No e-hearing was required in any of the matters
Penalties Imposed by ROC Pune
In each of the three adjudication orders, ROC Pune imposed the following penalties:
| Entity | Penalty per Order |
| Arcatron Mobility Private Limited | ₹1,00,000 |
| Ganesh Sharad Sonawane (Director) | ₹25,000 |
Aggregate Penalty Across Three Orders
Since the penalties were imposed separately for each independent default, the total penalty exposure works out as follows:
- Company: ₹1,00,000 × 3 orders = ₹3,00,000
- Director (Officer in Default): ₹25,000 × 3 orders = ₹75,000
Total cumulative penalty: ₹3,75,000
No penalty was imposed on the other directors in any of the three orders.
Compliance Directions
ROC Pune directed that, for each order:
- The default must be rectified
- Penalties must be paid within 90 days of receipt of the respective order
- Payment must be made through the MCA e-Adjudication portal
- The director’s penalty must be paid from personal sources
Appeals may be filed before the Regional Director, Mumbai, within 60 days, as per Section 454(5) and (6) of the Act.
Key Takeaways
- Multiple filings mean multiple penalties: each non-compliant MGT-14 was treated as a separate default
- Procedural lapses still attract monetary penalties, even without mala fide intent
- Suo-moto disclosure and Section 446B relief significantly limit penalty amounts
- Start-ups must ensure transaction-wise compliance, not just overall compliance
Conclusion
While Arcatron Mobility benefited from reduced penalties due to its start-up and small company status, the three ROC Pune orders demonstrate that repeated procedural lapses can cumulatively result in significant financial exposure.
In this case, independent defaults across three preferential allotments led to an aggregate penalty of ₹3.75 lakh, despite voluntary disclosure and absence of fraud.
ROC Pune Order PO/ADJ/01-2026/PU/01472 dated 23/01/2026: Arcatron Mobility penalised
ROC Pune Order PO/ADJ/01-2026/PU/01471 dated 23/01/2026: Arcatron Mobility penalised
ROC Pune Order PO/ADJ/01-2026/PU/01470 dated 23/01/2026: Arcatron Mobility penalised