DISCLOSURE OF CSR SPENDING IN PLAIN FORMAT INSTEAD OF TABULAR FORMAT IS A VIOLATION AS HELD BY ROC CHENNAI AND M/S SIVARAJ SPINNING MILLS PRIVATE LIMITED WAS FINED RS 10000 FOR NON-COMPLAINCE UNDER U/S 135(4)(A) OF THE COMPANIES ACT, 2013, R/W RULE 8 OF THE COMPANIES (CSR) RULES.

 DISCLOSURE OF CSR SPENDING IN PLAIN FORMAT INSTEAD OF TABULAR FORMAT IS A VIOLATION AS HELD BY ROC CHENNAI AND M/S SIVARAJ SPINNING MILLS PRIVATE LIMITED WAS FINED RS 10000 FOR NON-COMPLAINCE UNDER U/S 135(4)(A) OF THE COMPANIES ACT, 2013, R/W RULE 8 OF THE COMPANIES (CSR) RULES.

ROC,CHENNAI VS M/S SIVARAJ SPINNING MILLS PRIVATE LIMITED

WHY THIS CONCEERNS?

Section 135(4)(a) requires companies to include details of CSR activities in their Board’s Report in the manner prescribed.

Rule 8 of the CSR Rules mandates that CSR disclosures must follow the format provided in the annexure, which is tabular.

A plain-text disclosure, even if it contains the same information, is treated as a violation because it doesn’t comply with the statutory format.

ANNEXURE FORMAT FOR CSR DISCLOSURE (RULE 8)

S. No.

CSR Project or Activity Identified

Sector in which the project is covered

Projects or Programs (Local area/others)

Amount Outlay (Budget) Project or Program-wise

Amount Spent on the Projects or Programs (Direct or through implementing agencies)

Cumulative Expenditure up to the reporting period

Amount spent: Direct or through implementing agency

·       The table must include all CSR projects undertaken during the financial year.

·       Companies must specify whether the project is in the local area or elsewhere.

·       The disclosure must clearly show budgeted vs. actual expenditure.

·       Details of implementing agencies (if any) must be mentioned.

·       This format is mandatory — any deviation (like using plain text instead of the table) is treated as non-compliance, as seen in the Sivaraj Spinning Mills case.

KEY TAKEAWAY FOR COMPANIES:

·       CSR reporting is not just about substance but also form.

·       Even minor deviations (like not using the tabular format) can attract penalties.

·       Boards should ensure their CSR disclosures strictly follow the prescribed annexure to avoid fines and reputational risks.

·       This case is a reminder that compliance in corporate law often hinges on both content and format.

## YOUR COMPLIANCE PARTNER R V SECKAR, FCS, LLB 79047 19295,