Dudani Retail disclosed years of delayed statutory filings

Dudani Retail Limited, referred to as Dudani Retail, disclosed 92 delayed filings and returns across goods and services tax (GST), Registrar of Companies (RoC), Employees’ State Insurance Corporation (ESIC) and Employees’ Provident Fund Organisation (EPFO) requirements. The longest listed delay was 272 days for its first auditor-appointment filing in 2016, while GST-return delays ran from July 2017 to March 2025.

How extensive were Dudani Retail’s delayed statutory filings?

Dudani Retail’s disclosure shows that the lapses extended across 10 RoC filings and 82 GST, ESIC and EPFO return filings or payments. The 92-instance total is calculated from the schedules in the prospectus: 41 delayed GSTR-1 filings, 28 delayed GSTR-3B filings, 11 ESIC Form 5(A) filings, two EPFO Form 3A filings and 10 RoC forms. The listed record covers events from September 2016 through March 2026.

The nature of the delays varied by filing category and period. GSTR-1 and GSTR-3B are the two GST return forms identified in the disclosure, while RoC is the Registrar of Companies. Dudani Retail attributed most GST and labour-return delays to administrative delay, but it also cited COVID-19, server issues, a non-working portal and a non-working site for particular filings between March 2020 and April 2026.

The disclosure does not quantify any penalty, fine or interest associated with the 82 statutory-return delays. It states that future delays, defaults, penalties or fines cannot be ruled out and that any such event could affect Dudani Retail’s results of operations and financial position. The historical count therefore establishes the frequency of disclosed delays, but not a monetary liability from them.

What do Dudani Retail’s GST delays show over time?

Dudani Retail’s GST-return delays began with GSTR-3B for July 2017, filed eight days after the August 20, 2017 due date, and continued into 2025. Of the 69 GST delays listed, 41 concerned GSTR-1 and 28 concerned GSTR-3B. The latest GSTR-1 delay was for May 2024, filed two days late on June 13, 2024, while the latest GSTR-3B delay was for March 2025, filed two days late on April 22, 2025.

The longest GST delay was 100 days for GSTR-1 for March 2020, filed on July 20, 2020 against an April 11, 2020 due date, with COVID-19 given as the reason. The next-longest GSTR-1 delay was 70 days for April 2020. For GSTR-3B, the maximum was 72 days for March 2020, filed on July 1, 2020 against an April 20, 2020 due date; Dudani Retail described that entry as an administrative delay.

The pattern changed after 2021 in the disclosed GST schedules. GSTR-1 delays from October 2018 through September 2021 ranged from one to 100 days, with numerous delays exceeding 10 days, whereas the four listed GSTR-1 cases from July 2022 through May 2024 were between two and nine days. GSTR-3B entries after July 2021 ranged from one to 12 days, including two-day delays for December 2023 and March 2025 attributed to server issues.

Which corporate and labour filings were delayed?

Dudani Retail’s corporate filing record includes 10 delayed RoC forms, ranging from two days to 272 days late. The 272-day delay concerned Form ADT-1, its first auditor’s appointment, filed on December 26, 2016 against a September 23, 2016 due date. Other lengthy RoC delays included 270 days for an MGT-14 filing relating to conversion of unsecured loans into equity in 2021, and 215 days for a DPT-3 return of deposit filed in January 2023.

The more recent RoC entries were shorter but still occurred in 2025. Form DIR-12 for the appointment of Madhvi Sharma and Rajat Kasliwal was filed nine days late on January 28, 2025, while the cessation of Rajat Kasliwal was reported eight days late on September 12, 2025. Dudani Retail said it paid the requisite late fees for RoC filings, that all the forms were approved by the RoC, and that it had received no show-cause notice for those delays as of the prospectus date.

Labour-related filings appeared later in the schedule, from October 2022 onward. The 11 ESIC Form 5(A) delays ranged from one to 34 days, with the 34-day instance relating to July 2023 and filed on September 18, 2023. The two EPFO Form 3A entries were one day late for November 2024 and eight days late for March 2026, with the latter attributed to a site not working.

How is Dudani Retail addressing the compliance risk?

Dudani Retail says it has enhanced internal monitoring systems, assigned dedicated compliance personnel and engaged compliance professionals to streamline processes and prevent delays. The disclosed measures are a response to the GST, EPFO and ESIC delays rather than evidence that no further lapse will occur. The prospectus expressly says the company cannot assure investors that there will be no future delays, defaults, penalties or fines.

Dudani Retail separately disclosed a 2023 allotment-reporting discrepancy in e-Form PAS-3. A March 24, 2023 board resolution allotted 10,00,000 equity shares, but the original list of allottees attached to PAS-3 showed the three shareholders against incorrect allotment quantities. Dudani Retail filed a revised PAS-3 on May 13, 2026 and a compounding application under Section 441 of the Companies Act, 2013 with the RoC, Jaipur on May 19, 2026.

That PAS-3 matter is distinct from the 10 delayed RoC forms because it concerns an incorrect attachment rather than a late filing. It nevertheless illustrates that compliance monitoring requires both timely submission and accurate submitted data. Dudani Retail says regulatory authorities could impose penalties, start further proceedings or take an adverse view of the PAS-3 issue, and it gives no stated outcome for the May 2026 compounding application.

Conclusion

Dudani Retail’s disclosure describes a multi-category compliance record rather than an isolated filing failure: 69 delayed GST returns, 10 delayed RoC forms and 13 delayed ESIC and EPFO returns. The record spans nearly a decade from the September 2016 ADT-1 due date to the March 2026 labour-return events, although the most recent listed GST delays were generally shorter than the 2020 peak delays.

The next points to watch are whether the enhanced monitoring systems, dedicated personnel and external compliance professionals prevent further late filings, and how the RoC handles the May 19, 2026 PAS-3 compounding application. Dudani Retail disclosed no show-cause notice for the listed late RoC forms, but it also states that future penalties, fines or further delays cannot be assured against.