Talk to an Expert
Talk to an Expert ✆ +91 945 945 6700
Trusted by 10,000+ Businesses

LLP Partner Change in Pune - Expert CA/CS-Assisted Addition, Removal & Redesignation

Reviewed by CA and CS Team, Patron Accounting LLP ICAI & ICSI Registered| 15+ Years Experience| Last Updated: 23 March 2026 Verify Credentials →

Addition of Partner: Consent (Form 6) + Supplementary Agreement + Form 4 + Form 3 within 30 days

Resignation/Cessation: 30-day notice (or as per agreement) + Supplementary Agreement + Form 4 + Form 3 within 30 days

Designated Partner Change: DPIN/DIN mandatory + Indian resident requirement maintained + Form 4 within 30 days

Penalty: Rs 100 per day for late filing of Form 3/Form 4; no maximum cap

10,000+ Businesses Served | 4.9 Google Rating | 50,000+ Documents Filed | 15+ Years

15+ YearsIndustry Experience
CA & CSCertified Experts
4.9
Based on 500+ reviews

Get Free Consultation

Talk to a CA/CS expert today

🇮🇳 +91

    Our team will get back to you shortly. No spam.

    Real Stories from Real People

    Hear how teams across industries use Patron to save time, cut costs, & stay in control.

    Sunny Ashpal
    Sunny Ashpal
    Director - Demandify Media
    Google
    Anjanay Srivastava
    Anjanay Srivastava
    Founder - Hunarsource Consulting
    Google
    Mayur Shewale
    Mayur Shewale
    Founder - Bijasani Traders
    Google
    Ascendancy International
    Ascendancy International
    Owner
    Google

    I've had an outstanding experience working with my CA - Patron Accounting. Their professionalism, attention to detail, and timely communication made the entire process seamless and stress-free.

    I'm glad that I was able to connect with Patron. They took the minimum time to do the calculations based on the details provided by me and were really helpful throughout the process.

    Really a fantastic experience with Patron Accounting especially Shubham, he was extremely great. Knowledgeable person who deserves the 5 star for smooth handling of all documentation.

    Patron Accounting gives the best service related to all account handling of our firm. I am blessed and extremely happy that Patron Accounting assigned us a dedicated point of contact.

    I have called Patron to file ITR for my 5 family members. I worked with Shubham Junjunwala and Amin Jain. It was a smooth process. They understand basics very well and respond promptly.

    From the very beginning, their approach has been highly professional, prompt, and solution-oriented. Every interaction reflected their deep knowledge and commitment to helping clients.

    Very proficient and professional staff. Do fantastic job and instant response. Strongly recommended engaging them for all accounting needs specially for startups and growing businesses.

    I contacted them to file the ITR. Shubham was the POC for me and he was really very professional and giving prompt responses. Highly recommend them for tax and compliance work.

    Join 10,000+ Satisfied Businesses

    From startup co-founder exits to professional firm restructuring, Pune LLPs trust Patron for partner changes.

    Talk to an Expert
    10,000+Businesses ServedGST compliance and litigation support across India.
    15+Years ExperienceDeep expertise in IP registration, GST & business compliance.
    50,000+Documents FiledReturns, appeals, and filings handled accurately.
    4.9★Client RatingTrusted by entrepreneurs, startups, and growing businesses.
    ISO CertifiedProfessional standards and documented processes.
    SSL SecureYour financial and business data is fully protected.

    LLP Partner Change in Pune - Overview

    📌 TL;DR - LLP Partner Change in Pune Services at a Glance

    LLP partner change encompasses the addition, resignation, removal, redesignation, or change in particulars of partners and designated partners, governed by Sections 24 and 25 of the LLP Act, 2008 and Rules 21-22 of the LLP Rules, 2009. Every change requires: amendment of the LLP Agreement (via supplementary agreement on stamp paper), filing Form 4 (notice of change in partners) and Form 3 (change in LLP Agreement) with ROC within 30 days, and maintaining the mandatory minimum of two designated partners (at least one Indian resident) at all times. Late filing attracts Rs 100 per day penalty with no cap.

    Pune's LLP ecosystem drives frequent partner changes. IT consulting LLPs in Hinjewadi and Kharadi add new partners as businesses grow or manage co-founder exits. Professional services LLPs in Shivajinagar and Koregaon Park manage partner retirements, promotions, and lateral hires. Trading LLPs in Baner and Wakad add family members. Manufacturing LLPs in Pimpri-Chinchwad handle succession. The ROC Pune at Shivajinagar processes all Form 3 and Form 4 filings via MCA V3. Learn more about LLP Partner Change across India.

    The critical compliance requirement: the LLP must always maintain minimum 2 designated partners, at least one of whom must be an Indian resident (120+ days in preceding FY). If a designated partner's resignation reduces the count below 2, a replacement must be appointed before the resignation takes effect. After partner changes, LLPs benefit from LLP Compliance in Pune and Accounting Services.

    Content is reviewed quarterly for accuracy.

    What Is LLP Partner Change - Partner vs Designated Partner

    LLP partner change is the statutory process of modifying the partnership composition - adding new partners, removing existing ones, redesignating partners as designated partners (or vice versa), or updating partner particulars. Under the LLP Act, 2008, any individual or body corporate can be a partner, but designated partners must be individuals, must hold a DPIN/DIN, and at least one must be an Indian resident.

    A partner contributes capital, shares profits/losses, and participates in operations. A designated partner has additional statutory responsibilities: signing MCA forms, maintaining books, filing Form 8 and Form 11, ensuring compliance, and acting as legal representative. Every LLP must have minimum 2 designated partners at all times. Regular partners do not need DPIN/DIN - only PAN suffices.

    For Pune LLPs, partner changes require: reviewing the LLP Agreement, obtaining partner approvals, drafting supplementary agreement (on Maharashtra stamp paper), filing Form 4 and Form 3 with ROC Pune within 30 days, and updating books of accounts (capital account adjustments).

    Key Terms for LLP Partner Change in Pune:

    Form 4: Notice of appointment, cessation, or change in particulars of partners/designated partners. Filed within 30 days on MCA V3.

    Form 3: LLP Agreement amendment (supplementary agreement attached). Filed within 30 days alongside Form 4.

    Form 6: Consent of incoming partner to become partner/designated partner. Submitted to the LLP before Form 4 filing.

    DPIN/DIN: Mandatory for designated partners only (not regular partners). Applied via Form DIR-3. DPIN and DIN are interchangeable.

    Schedule I: Default provisions when LLP Agreement is silent. Key: majority cannot expel a partner. 30-day resignation notice. All partners must consent for new admission.

    APL-05 LLP Partner Change in Pune
    Form 4 + Form 3 Within 30 Days

    Who Needs LLP Partner Change in Pune

    IT Consulting LLPs (Hinjewadi, Kharadi) - Growing from 2-3 person operations to larger firms, adding senior consultants as equity partners. Also managing co-founder exits during strategic disagreements. See LLP Compliance in Pune for annual filing after partner changes.

    Professional Services LLPs (Shivajinagar, Koregaon Park, Baner) - CA/CS/law/consulting firms managing continuous partner lifecycle: retiring seniors, promoting associates to partner, elevating partners to designated partner, and bringing in lateral hires.

    LLPs with Co-Founder Exits (Hinjewadi, Baner) - When a co-founder wants to leave due to disagreements or new ventures. Careful management needed for capital settlement, profit-sharing adjustment, and minimum designated partner count.

    LLPs Adding Investors as Partners - Individuals or body corporates joining as partners. If investor will be designated partner, DPIN/DIN required. Supplementary agreement must detail capital, profit-sharing, and governance rights.

    Family Business LLPs (Pimpri-Chinchwad, Hadapsar) - Adding next-generation members while retiring older family members. Admission and cessation often within the same filing cycle.

    LLP Partner Change Services in Pune

    ServiceWhat We Do
    Addition of New PartnerConsent from all existing partners, new partner consent (Form 6), supplementary agreement with capital and profit-sharing, Form 4 + Form 3 filing, books update
    Addition of Designated PartnerDPIN/DIN application (Form DIR-3), DSC procurement, Indian residency verification, consent, supplementary agreement, Form 4 + Form 3, DIR-3 KYC setup
    Partner Resignation/CessationProcessing resignation letter, ensuring minimum 2 DPs maintained, supplementary agreement, capital settlement advisory, Form 4 + Form 3 filing
    Partner Removal/ExpulsionLLP Agreement removal provisions review (Schedule I if silent), partner meeting, resolution, supplementary agreement, Form 4 + Form 3
    Redesignation (Partner to DP)DPIN/DIN application, DSC procurement, supplementary agreement, Form 4, DIR-3 KYC annual compliance setup
    Post-Change Compliance CascadeBank signatories, GST authorized signatory, PF/ESIC signatories, statutory registers, Form 8/Form 11 alignment, DIR-3 KYC
    Our Process

    LLP Partner Change Process in Pune

    6-step guide for partner addition, removal, and redesignation

    Step 1

    Review LLP Agreement and Determine Change Type

    Examine the existing LLP Agreement for provisions regarding admission, resignation, removal, and redesignation. Key questions: Does it require unanimous or majority consent? What is the notice period for resignation (30 days if silent)? Can a partner be removed - if agreement is silent, Schedule I says majority cannot expel. Determine whether the change involves a partner (no DPIN needed) or designated partner (DPIN/DIN mandatory).

    Agreement ReviewedChange Type Mapped
    Pathway Identified01
    Step 2

    Obtain DPIN/DIN for New Designated Partner (If Applicable)

    If the new partner will be a designated partner, they must hold DPIN/DIN (interchangeable). If they already hold a DIN from a company directorship, no separate DPIN needed. Otherwise, apply through Form DIR-3 on MCA portal. Requirements: Class III DSC, PAN, Aadhaar, passport-size photo, address proof. Processing: 3-7 working days. Regular partners do not need DPIN/DIN.

    DPIN/DIN AppliedDSC Procured
    DPIN
    Identity Verified02
    Step 3

    Pass Partner Resolution and Obtain Consent

    Conduct meeting of all existing partners. Pass resolution approving the change. For addition: record new partner details, capital, profit-sharing. Obtain new partner consent in Form 6. For resignation: accept written resignation. Ensure minimum 2 designated partners (at least 1 Indian resident) will be maintained. If a DP is leaving, appoint replacement BEFORE filing cessation.

    Resolution PassedMinimum DPs Verified
    RES
    Consent Obtained03
    Step 4

    Draft and Execute Supplementary LLP Agreement

    Prepare supplementary agreement amending the original: addition/removal of partner, revised details, capital changes, profit-sharing changes, governance changes. Executed on proper non-judicial stamp paper per Maharashtra Stamp Act. Signed by all partners (existing and new), witnessed, and notarized (recommended). Patron drafts and coordinates Maharashtra stamp duty.

    On Stamp PaperAll Partners Signed
    Agreement Executed04
    Step 5

    File Form 4 and Form 3 with ROC Pune Within 30 Days

    File both forms on MCA V3 within 30 days of the change: Form 4 (partner change details - DPIN/DIN/PAN, address, designation, capital, effective date) and Form 3 (supplementary agreement attached). Both digitally signed by designated partners. Patron files both as a coordinated pair and tracks ROC Pune approval.

    Form 4 FiledForm 3 Filed
    F4F3
    ROC Filing Complete05
    Step 6

    Update Books and Complete Post-Change Compliance

    Adjust partner capital accounts (credit incoming, debit outgoing settlement). Update profit-sharing schedule. Ensure revised information in next Form 11 (due 30 May) and Form 8 (due 30 October). Update bank signatories, GST authorized signatory, EPFO/ESIC if applicable. Set up DIR-3 KYC for new designated partners (due 30 September). Patron manages the complete cascade.

    Books UpdatedBank + GST Updated
    Change Complete06

    Documents Required for LLP Partner Change in Pune

    Existing LLP Agreement: To review admission/removal/redesignation provisions.

    Partner Resolution: Approving the change; signed by all existing partners.

    New Partner Consent (Form 6): Written consent to become partner/designated partner.

    Resignation Letter: From outgoing partner with effective date and 30-day notice.

    Supplementary LLP Agreement: On Maharashtra stamp paper; signed by all partners; witnessed.

    DPIN/DIN Certificate: For new designated partners (Form DIR-3 approval).

    DSC: Class III DSC for designated partners filing MCA forms.

    PAN + Aadhaar + Address Proof: Of incoming/outgoing partner (mandatory for Form 4 and DIR-3).

    Pune-Specific Tip: For Pune IT consulting LLPs in Hinjewadi and Kharadi adding a foreign national or NRI as partner, FEMA compliance is required. FDI in LLPs is permitted only in sectors where 100% FDI is allowed under the automatic route. LLP(I) form with RBI is also required. Patron coordinates both MCA and FEMA compliance.

    Common LLP Partner Change Challenges in Pune

    ChallengeImpactHow Patron Accounting Solves It
    Minimum Designated Partner ViolationFiling cessation before appointing replacement leaves LLP below 2 DPs; ROC may reject Form 4Incoming DP appointment processed BEFORE outgoing cessation in single coordinated filing; minimum count never breached
    Removal vs Resignation ConfusionSchedule I (if agreement silent) says majority CANNOT expel minority partner; attempted removals without agreement provisions are legally invalidAgreement reviewed first; legally valid pathway advised; removal provisions identified or voluntary resignation negotiated
    Form 3 and Form 4 Not CoordinatedFiling Form 4 without Form 3 creates MCA inconsistency - partner list updated but agreement unchangedBoth forms always filed as coordinated pair within 30 days; SRN tracked for both
    Capital Settlement DisputesExiting partner capital account contentious - goodwill, undistributed profits, appreciated assets not in booksFair settlement computation; methodology documented in supplementary agreement; reflected properly in books
    DIR-3 KYC Deactivation of New DPNewly appointed designated partner misses 30 September DIR-3 KYC deadline; DIN deactivated; blocks all MCA filingsDIR-3 KYC set up immediately upon appointment; proactive filing before September deadline

    LLP Partner Change Fees in Pune

    Fee ComponentAmount
    Patron Accounting Professional Fees (LLP Partner Change)Starting from INR 999/mo (Exl GST and Govt. Charges)
    Addition of New Partner (Complete)Rs 5,000 - Rs 15,000 (consent + agreement + Form 3 + Form 4)
    Addition of Designated PartnerRs 8,000 - Rs 18,000 (DPIN/DIN + DSC + consent + agreement + Form 3/4)
    Partner Resignation/CessationRs 5,000 - Rs 12,000 (settlement advisory + agreement + Form 3/4)
    Partner Removal/ExpulsionRs 8,000 - Rs 20,000 (agreement review + resolution + Form 3/4)
    Redesignation (Partner to DP)Rs 5,000 - Rs 12,000 (DPIN + agreement + Form 4)
    DPIN/DIN Application (DIR-3)Rs 2,000 - Rs 5,000 (DSC + MCA filing)
    Post-Change Compliance CascadeRs 3,000 - Rs 10,000 (bank + GST + EPFO/ESIC + DIR-3 KYC)
    Government FeesMCA filing fees for Form 3 (based on contribution) and Form 4. Maharashtra stamp duty on supplementary agreement. Late: Rs 100/day per form (no cap)

    All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

    Professional service charges for drafting, filing, and representation are separate from the statutory fees. The exact fee depends on the complexity of the case, disputed amount, and number of hearings required. Contact us for a detailed quote.

    Get a free LLP Partner Change in Pune consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

    LLP Partner Change Timeline

    StageEstimated Timeline
    Review LLP Agreement + Determine ChangeDay 1-2
    DPIN/DIN Application (if new DP)3-7 working days (parallel)
    Partner Meeting + Resolution + Consent (Form 6)Day 3-5
    Draft Supplementary AgreementDay 5-10
    Maharashtra Stamp Duty + ExecutionDay 10-15
    Form 3 + Form 4 Filing on MCA V3Within 30 days of change
    ROC Pune Processing7-15 working days
    Post-Change Compliance (Bank, GST, DIR-3 KYC)Within 30 days of ROC approval

    Pune Processing Note: ROC Pune at Shivajinagar processes Form 3 and Form 4 via MCA V3. Maharashtra stamp duty on supplementary agreement via IGR e-stamping or franking. Total timeline: 15-25 days for standard partner change. DPIN/DIN application may add time if not already held. Critical: Form 4 and Form 3 must BOTH be filed within 30 days as a coordinated pair. The 30-day clock starts on the date of admission/cessation, not the agreement execution date. Patron coordinates from its Wagholi office.

    Key Benefits

    Why Choose Patron for LLP Partner Change in Pune

    Pune Office at Wagholi

    Serving IT consulting LLPs, professional services LLPs, trading LLPs, and manufacturing LLPs across Hinjewadi, Kharadi, Baner, Koregaon Park, Wakad, Pimpri-Chinchwad.

    5-Scenario Coverage

    All partner change types handled: addition, resignation, removal, redesignation, and particulars change - with coordinated Form 3 + Form 4 as standard practice.

    Minimum DP Safeguard

    Incoming designated partner appointment always processed BEFORE outgoing partner cessation, preventing minimum partner count violations that block MCA filings.

    Integrated Compliance

    Partner change managed alongside agreement drafting, Maharashtra stamp duty, capital updates, bank signatory changes, and DIR-3 KYC setup - all in one engagement.

    Trusted by Pune LLPs

    10,000+ Businesses | 4.9 Google Rating | 50,000+ Docs Filed | 15+ Years

    Trusted by Hyundai, Asian Paints, Bridgestone, and 10,000+ businesses across India. Patron Accounting LLP itself operates as an LLP - we understand partner changes from firsthand experience. Offices in Pune, Mumbai, Delhi, and Gurugram.

    Patron vs Local CA Firms in Pune

    FactorPatron AccountingTypical Local Consultant
    5-Scenario CoverageAll partner change types handledOnly addition/resignation
    Form 3 + Form 4 CoordinationAlways filed as coordinated pairForm 4 filed; Form 3 often missed
    DPIN/DIN ApplicationEnd-to-end DSC + DIR-3 processingClient manages separately
    Agreement DraftingProfessional + Maharashtra stamp dutyTemplate-based; stamp duty uncertain
    Minimum DP SafeguardIncoming before outgoing - alwaysFiling sequence not controlled
    Post-Change CascadeBank + GST + EPFO + DIR-3 KYCClient updates separately

    Related Services for Pune LLPs

    Pune LLPs managing partner changes often need complementary services:

    Legal and Compliance Framework for LLP Partner Change

    Section 7: Minimum 2 partners. If reduced to 1 and not restored within 6 months, sole partner carries unlimited liability.

    Section 7(1): Minimum 2 designated partners; at least 1 Indian resident (120+ days in preceding FY).

    Section 25: Change in partners notified to ROC within 30 days (Form 4). Partner notifies LLP within 15 days of name/address change.

    Schedule I: Applies when agreement is silent. Majority cannot expel. 30-day resignation notice. All partners consent for new admission.

    DPIN/DIN: Interchangeable. Mandatory for designated partners only. Applied via Form DIR-3.

    Penalty: Rs 100/day for late Form 3 and Form 4. No cap. Applies from 31st day after change.

    Portal: MCA V3 - mca.gov.in

    ROC Pune: Shivajinagar.

    How to add a new partner to an LLP?

    Obtain consent of all existing partners (or per LLP Agreement), secure new partner written consent (Form 6), draft supplementary LLP Agreement on Maharashtra stamp paper detailing capital and profit-sharing, and file Form 4 + Form 3 with ROC Pune via MCA V3 within 30 days. New designated partners must first obtain DPIN/DIN via Form DIR-3. Update books with capital account.

    Is DPIN/DIN required for all LLP partners?

    No. DPIN/DIN is mandatory only for designated partners, not regular partners. Regular partners are identified by PAN number in Form 4. DPIN and DIN are interchangeable - if a person already holds a DIN from company directorship, same number serves as DPIN. New designated partners apply through Form DIR-3 requiring Class III DSC, PAN, Aadhaar, photo, and address proof.

    Can a partner be removed from an LLP?

    Depends on the LLP Agreement. If removal provisions exist, they must be followed precisely. If the agreement is silent, Schedule I applies - majority of partners cannot expel a minority partner. Options include negotiating voluntary resignation, amending the agreement to include removal provisions, or approaching the NCLT. Patron reviews the agreement and advises the legally valid pathway.

    What is the penalty for late filing?

    Rs 100 per day from the due date (30 days after the change) for both Form 3 and Form 4. No maximum cap. Filing both forms 6 months late costs approximately Rs 36,000 (Rs 100 x 180 days x 2 forms). Penalty applies regardless of LLP size or turnover. Patron files both forms within the first week after agreement execution.

    What is the minimum number of partners in an LLP?

    Minimum 2 partners at all times, with at least 2 designated partners (at least 1 Indian resident). If partners fall below 2 and not restored within 6 months, the sole partner carries unlimited personal liability. If a designated partner resigns reducing count below 2, replacement must be appointed before cessation is filed. No maximum limit on partners.

    Does partner change affect profit sharing?

    Not automatically. A change in partners does not automatically change the profit-sharing ratio unless the LLP Agreement or supplementary agreement expressly provides for it. If a new partner is joining with capital, the supplementary agreement must explicitly state whether ratios change. If an existing partner is leaving, their share must be redistributed per the agreement.

    Can a body corporate be a partner in an LLP?

    Yes. A body corporate (company, another LLP, or any corporate entity) can be a partner but cannot be a designated partner - only individuals can. The body corporate must pass a resolution authorizing its appointment and nominate an individual representative. The representative's details are filed in Form 4.

    What happens when a partner dies?

    Death does not dissolve the LLP - remaining partners continue. The deceased partner's capital account balance is settled with legal representatives per the LLP Agreement. If the deceased was a designated partner, a replacement must be appointed immediately to maintain the minimum count. Form 4 (cessation) and Form 3 (supplementary agreement) filed within 30 days.

    Quick Answers

    How to change partner in LLP? Review agreement > Obtain consent/resignation > Supplementary agreement on Maharashtra stamp paper > Form 4 + Form 3 with ROC within 30 days. Designated partner needs DPIN/DIN. Maintain minimum 2 DPs (1 Indian resident) always.

    Pune mein LLP partner kaise change karein? LLP agreement check karein. Partner ki consent/resignation lein. Supplementary agreement stamp paper par banayein. MCA V3 portal par Form 4 aur Form 3 file karein 30 din mein. Patron Pune office se sab handle karta hai.

    What is the penalty? Rs 100 per day per form (Form 3 and Form 4) with no cap. 6-month delay on both forms = Rs 36,000.

    File Partner Change Forms Before Penalties Accumulate

    Form 4 and Form 3 must both be filed within 30 days of the partner change. Rs 100/day penalty per form with no cap means a 3-month delay costs Rs 18,000. The minimum 2 designated partners requirement is absolute - filing cessation before appointing a replacement can cause ROC rejection.

    DPIN/DIN for new designated partners must be obtained BEFORE the appointment date (3-7 days processing). The supplementary agreement must be on proper Maharashtra stamp paper. For LLPs adding foreign partners, FEMA compliance adds a parallel track. Patron manages the complete coordinated process from its Wagholi office.

    Get Expert LLP Partner Change in Pune

    LLP partner change in Pune is a multi-step compliance process covering addition, resignation, removal, redesignation, and change in particulars - each requiring amendment of the LLP Agreement, coordinated Form 3 and Form 4 filing with ROC Pune within 30 days, and maintenance of minimum 2 designated partners.

    Patron Accounting's Pune office at RTC Silver, Wagholi provides end-to-end LLP partner change services covering all five scenarios, DPIN/DIN application, supplementary agreement with Maharashtra stamp duty, coordinated Form 3/4 filing, and complete post-change compliance cascade.

    As an LLP itself, Patron understands partner changes from firsthand experience. With 15+ years of practice and 10,000+ businesses served, Patron Accounting LLP is a trusted CA and CS firm across Pune, Mumbai, Delhi, and Gurugram.

    Book a Free Consultation - No Obligation.

    LLP Partner Change Services Across India

    Patron Accounting provides LLP partner change services in 4 major cities.

    Pune
    Maharashtra
    You're here
    Mumbai
    Maharashtra
    Delhi
    Delhi NCR
    Gurugram
    Haryana

    Content Created: 23 March 2026  |  Last Updated: 23 March 2026  |  Next Review: September 2026  |  Reviewed By: CA & CS Team, Patron Accounting LLP

    This page on LLP Partner Change in Pune is reviewed semi-annually. Content covers Sections 7/24/25 LLP Act 2008, Rules 21-22 LLP Rules 2009, Form 4 (partner change), Form 3 (agreement amendment), Form 6 (consent), DPIN/DIN (Form DIR-3), Schedule I default provisions, minimum 2 designated partners (1 Indian resident), Rs 100/day penalty with no cap, and ROC Pune jurisdiction. Freshness Tier 2.