EPF - department demands minimum admin charges from April 2014 to March 2017

I have a doubt on EPF admin charge applicability to a firm which has not registered with EPF. My company have att ained the employee strength on April 2014, but all employees of the company are above the EPF ceiling and the contribution of employees engaged through contractor were remitted by the contractor. So we have not registered with EPFO. during 2017-18 company changed its policy and eliminated all contractors and absorbed the employees engaged through contractor to its payroll and registered with EPFO. Now we are remitting EPF contributions regularly. after the inspection the department demands minimum admin charges from April 2014 to March 2017. whether we are liable to remit the same even we are not registered. Please advice.

on 1st instance the minimum admin charges are payable by the establishment who was liable to pay EPF in that specific period,
but if it is found that the contractor had no other contract other than this principal then department establish that the contractor is the unit of principal only.
if you can produce form 5/7/12/13/14 of contractor in your support that you have maintained CLRA act fully then department will initiate the proceeding to the contractor, otherwise the principal is liable

In any establishment if more than 20 employees are engaged directly or indirectly irrespective if they fall under PF deduction criteria or not, the establishment needs to be got registration under EPF act 1952. Thereafter, if there is no employee who falls under PF deduction, the establishment has to generate challan paying minimum admin charges of Rs. 500/- per month.