Annu Projects cannot trace 13 filings and seeks CSR adjudication

Annu Projects has disclosed that 13 historical corporate filing records and secretarial forms cannot be traced, while it filed a petition seeking adjudication before the Registrar of Companies (RoC) on May 16, 2026 over earlier corporate social responsibility (CSR) non-compliance. The unspent CSR amount was Rs 36.7 lakh across Fiscal 2021 and Fiscal 2022.

What historical corporate filings and records cannot Annu Projects trace?

Annu Projects cannot trace 13 corporate records and secretarial forms spanning share allotments, director appointments, annual returns, financial statements, auditor appointments and charge filings from Fiscal 2003 through Fiscal 2014. Annu Projects said it used alternative evidence, including board resolutions and other supporting documents held in its records, when preparing disclosures in its Red Herring Prospectus.

The missing material includes Form 2 for the December 15, 2003 allotment of 50 equity shares each to Gita Devi Sarraf and Gopal Kumar. It also includes Form 32 records for the August 31, 2003 appointments of Krishna Ranjan and Swarawan Kumar Sarraf as additional directors, and for their confirmation as directors at the September 24, 2004 annual general meeting (AGM).

Annu Projects said Umesh Ved & Associates, a practising company secretary, conducted online and physical searches of records available at the RoC. In its August 18, 2026 report, the firm confirmed that the historical records were unavailable after inspecting documents maintained by Annu Projects, the Ministry of Corporate Affairs portal and the RoC.

Why does the unavailable 2003 transfer agreement matter?

Annu Projects also does not have the business transfer agreement under which it acquired Annu Enterprises in Fiscal 2003. Annu Enterprises was a sole proprietorship of promoter Sanjay Kumar Sarraf, making the unavailable agreement relevant to documentation of the transaction through which Annu Projects acquired the business.

The disclosure does not state a financial value for the Fiscal 2003 transfer or allege that the acquisition was invalid. It says only that the agreement copy is unavailable, alongside discrepancies in certain forms submitted by Annu Projects. Annu Projects further disclosed delayed filing of Form MSME-1 and Form ADT-1, and said it paid an additional fee for the late ADT-1 filing.

No legal proceeding had been initiated against Annu Projects as of the Red Herring Prospectus date in relation to the untraceable records. The stated risk is prospective: statutory authorities could initiate regulatory action or impose monetary penalties if discrepancies in secretarial filings or corporate records are identified, depending on future regulatory review and the authorities' assessment of the filings and available alternative documents.

What is the status of Annu Projects' CSR non-compliance?

Annu Projects has sought RoC adjudication regarding unspent CSR amounts of Rs 18.6 lakh for Fiscal 2021 and Rs 18.1 lakh for Fiscal 2022, after first applying for compounding. CSR is the corporate social responsibility spending requirement described in the Companies Act, and the two fiscal-year shortfalls together were Rs 36.7 lakh.

Annu Projects said it did not spend those CSR amounts in the respective fiscal years and inadvertently did not state reasons for the non-spending as required under Section 134(3)(o) of the Companies Act. Annu Projects subsequently spent the Fiscal 2021 and Fiscal 2022 CSR amounts during Fiscal 2026, but its disclosure identifies a separate issue under rules applicable from January 22, 2021.

The Companies Amendment Act, 2019 became effective on January 22, 2021. As described by Annu Projects, companies could not use CSR funds required for one fiscal year in another fiscal year unless the amount related to an ongoing project; otherwise, the unspent amount had to be transferred to a fund specified in Schedule VII of the Companies Act.

Annu Projects submitted a compounding application to the RoC on July 30, 2025, then applied to withdraw it on December 10, 2025 following an internal review. It subsequently filed its adjudication petition on May 16, 2026. The disclosure says penalties may be imposed on Annu Projects and its responsible officers, but does not quantify a potential penalty or report an adjudication outcome.

What other corporate compliance matter remains pending?

Annu Projects has received a stamp-duty notice that remains pending, separate from the historical filing-record and CSR matters. The Office of the Collector of Stamps (Headquarters), Government of the National Capital Territory of Delhi, issued the notice on June 23, 2026, alleging non-payment or short payment of stamp duty related to a share allotment.

The notice concerns Form PAS-3 bearing service request number AA9862592, dated August 20, 2024. Annu Projects did not disclose a claimed stamp-duty amount, provision or resolution of the matter. Its stated exposure is that a major penalty could affect operations and financial condition, while the eventual result remains subject to the pending process.

A further administrative item concerns the registered-office address. Annu Projects passed a June 24, 2025 resolution to correct “Shoping” to “Shopping” in the address at B-1, Plot No. 11, Local Shopping Complex, Vasant Kunj, South Delhi, New Delhi - 110070; it said it cannot assure that authorities will update their records.

Conclusion

Annu Projects' disclosure identifies a governance and documentation record extending from Fiscal 2003 to Fiscal 2014, rather than a single late filing. The 13 untraceable records and forms, missing Fiscal 2003 business-transfer agreement, delayed MSME-1 and ADT-1 forms, and Rs 36.7 lakh CSR shortfall create separate compliance questions with different records, periods and regulatory mechanisms.

The next disclosed milestones are the RoC's treatment of the May 16, 2026 CSR adjudication petition and the outcome of the June 23, 2026 Delhi stamp-duty notice. It will also matter whether Annu Projects or the RoC locates any of the historical documents confirmed unavailable in the August 18, 2026 search report, or whether authorities act on the cited filing discrepancies.