S. K. Offset reports long filing delays and missing records

S. K. Offset Limited disclosed a 1,689-day Registrar of Companies filing delay, late tax and employee-fund payments, unavailable e-form challans and untraceable records related to historical equity allotments. The company says it has regularised identified filings, but it cannot rule out future proceedings or monetary penalties for earlier lapses.

What compliance lapses did S. K. Offset disclose?

S. K. Offset disclosed 15 delayed filings with the Registrar of Companies, or RoC, the authority that records company-law filings. The longest was Form ADT-1, which records appointment of an auditor: an event dated September 30, 2014 was due for filing on October 14, 2014 but was filed on May 30, 2019, or 1,689 days late. A DIR-12 form for regularisation of a director after a September 26, 2022 event was filed on May 1, 2026, 1,283 days after its October 26, 2022 due date.

The remaining disclosed RoC delays ranged from three days to 195 days. S. K. Offset filed a CHG-4 form for satisfaction of charge 195 days after its October 30, 2025 due date, and filed an MGT-14 form relating to approval for conversion of loan into equity 154 days late. A PAS-3 return of allotment for a December 8, 2025 event was filed 63 days late, while an MSME-1 return for the half-year ended March 31, 2026 was filed 57 days late on June 26, 2026.

S. K. Offset said the delayed forms were subsequently filed after payment of the additional fee prescribed by the RoC. It attributed the cases to the absence of proper systems and teams, and said it has appointed a Company Secretary and Compliance Officer to manage secretarial processes. The company nevertheless said it cannot confirm that authorities will not act on the past filing instances.

How extensive were S. K. Offset's tax and labour payment delays?

S. K. Offset reported delayed Goods and Services Tax, or GST, filings and payments in Fiscal 2024 through Fiscal 2026. The longest listed GST delay was 12 days for July in Fiscal 2026, where a payment or return due August 20, 2025 was made or filed on September 1, 2025. The largest listed GST amount was Rs 6.95813 lakh for June in Fiscal 2026, paid or filed nine days after the July 20, 2025 due date.

Tax deducted at source, or TDS, payment delays were longer. S. K. Offset listed a Rs 10 TDS payment for February that was due March 7, 2024 and paid on October 28, 2024, a 235-day delay. The largest listed delayed TDS payment was Rs 17.316 lakh for March, due April 30, 2026 and paid September 9, 2026, with a stated delay of 132 days.

The company also disclosed one delayed TDS return in its Fiscal 2023-24 table. That table lists the first-quarter return as due July 31, 2022 and filed September 19, 2023, while stating a 51-day delay. TDS payments transfer withheld tax, whereas TDS returns report withholding information to tax authorities.

Did employee-fund delays become less frequent over time?

S. K. Offset disclosed recurring late Employee Provident Fund, or EPF, and Employees' State Insurance Corporation, or ESIC, deposits in Fiscal 2023-24, Fiscal 2024-25 and Fiscal 2025-26. EPF is a retirement-savings contribution system, while ESIC provides employee social insurance. All 12 listed EPF payments in Fiscal 2023-24 were late, with delays from two days to 114 days; the August payment of Rs 11,525, due September 15, 2023, was paid January 7, 2024.

The listed number of late EPF payments declined in later periods, although the disclosure does not establish that all unlisted payments were timely. Fiscal 2024-25 included five listed late EPF payments, ranging from four days to 65 days, while Fiscal 2025-26 included two, of 18 days and two days. The June Fiscal 2025-26 EPF payment of Rs 38,373 was due July 15, 2025 and paid August 2, 2025.

The ESIC record follows a similar pattern. Fiscal 2023-24 had 11 listed late ESIC payments, including a Rs 640 July payment made 145 days late and a Rs 8,379 August payment made 114 days late. Fiscal 2024-25 had five listed delayed ESIC payments, and Fiscal 2025-26 had one: Rs 17,073 for June, paid 18 days after its July 15, 2025 due date.

S. K. Offset said employees required to be registered under the applicable EPF and ESIC basic-wage limits have been registered, and that it is deducting and depositing the contributions for those employees. The company also said it obtained opt-out letters from employees who did not wish to avail EPF and ESIC facilities. It has engaged independent labour-law consultants for routine and event-based compliance advice.

Why do the missing RoC records matter for S. K. Offset?

S. K. Offset said challans for various e-forms filed with the RoC were unavailable. A challan is the receipt or payment evidence associated with an electronic filing. The company therefore compiled the disclosed 15-item filing history using an August 31, 2026 Search Report from Vinay Terse & Associates, a practising company secretary, rather than relying on a complete archive of its own filing receipts.

The company also disclosed that some historical equity-share allotments and transfers were not in strict compliance with the Companies Act, 1956 and the Companies Act, 2013. It said consideration for certain allotments or transfers was stated to have been received in cash, but independent documentary evidence of receipt was unavailable. S. K. Offset relied on statutory registers, minute books and certificates from an independent chartered accountant to establish the allotment details, nature of allotment and consideration received.

The untraceable record set includes Form 3 dated April 1, 2007, Form 2 dated April 30, 2007 and March 31, 2008, Form 32 dated January 18, 2013, and Form 24 ACA for seven financial years from 2007-08 through 2013-14. S. K. Offset said it wrote to RoC Uttar Pradesh II on June 12, 2026 seeking copies or confirmation, but had not received the relevant records or conclusive communication as of the prospectus date.

What actions has S. K. Offset taken and what remains unresolved?

S. K. Offset said it has regularised the identified tax, labour and filing delays. Its stated measures include appointment of a whole-time Company Secretary with more than 10 years of experience, stronger regulatory-compliance controls under the Chief Financial Officer and Compliance Officer, and independent consultants for EPF and ESIC matters. These measures address future filing processes but do not remove the disclosed uncertainty over historical forms and records dating from 2007.

S. K. Offset had not filed an application for adjudication or compounding of offences under applicable law as of the prospectus date. The company said no legal proceedings or regulatory action had been initiated over the RoC lapses, discrepancies, incorrect filings or filing delays, but it cannot assure that proceedings or penalties will not arise. It undertook that any regulatory penalty, if levied, would be met from internal accruals rather than initial public offering proceeds.

Conclusion

S. K. Offset’s disclosures show that the compliance issue extends beyond isolated late payments. The record includes a 1,689-day RoC filing delay, repeated delayed EPF and ESIC deposits in Fiscal 2023-24, delayed TDS payments including Rs 17.316 lakh in 2026, unavailable e-form challans and incomplete evidence for certain historical share transactions.

The next development to watch is the outcome of S. K. Offset’s June 12, 2026 request to RoC Uttar Pradesh II for historical records or confirmation. The company has also left unresolved whether regulators will initiate action over the earlier lapses, while disclosing that any resulting penalty would be paid from internal accruals.