RABINDRA CHAMRIA vs THE REGISTRAR OF COMPANIES, W.B. .

The Supreme Court examined the applicability of Section 633 of the Companies Act, 1956, in relation to liabilities under the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952. The Court held that Section 633 provides relief from liability only for proceedings under the Companies Act and does not extend to liabilities arising under other statutes. Consequently, the appeals seeking relief under Section 633 for non-payment of provident fund dues were dismissed, affirming the Division Bench's interpretation that 'any proceeding' refers solely to those under the Companies Act.