Who is liable to file 'Form D' (under payment of Bonus At, 1965 )in case of Contract workers ? Principle Employer or Contractor ?

My company had filed 'Form D' for company workers and HR manager says that the contractor has to file/submit 'Form D' for contract workers and company is not liable.
The company pays the bonus to contractors which contractors paid to his workers so a company is paying indirectly.
What if the contractor fails to submit the 'Form D'? is the company is liable to file itself in this case or to just ensure that the contractor has filed. what if the contractor fails to fie 'Form D' as well as the penalty of that.
consider that most of the contractors are not older than 5 years.
Kindly give me answer for this Asap. thanks in advance.

Dear Ano...
The employer i.e. the contractor should file form D as a Principal employer your company shall ensure the compliance.
Shailesh Parikh
99 98 97 10 65
Vadodara

yes , That is clear ..but what if the contractor has not filed?
As a principle employer do we have any penalty upon us?

As per Payment of Bonus Act 1965, the principal employer owes no responsibility for compliance of the Act by the contractor. It is only the contractor who can be held responsible under the Act. But from IR point of view, the Principal Employer takes an active interest in ensuring due compliance by the contractor