You shall be eligible for promotion from 2019 but there should be retrospective promotion it shall be deemed on date you should be promoted but since you are under penalty and rule specifies that both will run simultaneously so company won't give it retrospectively, it should be challanged before high court if your are not being promoted retrospectivly.
Under rule 36 of CDA rules the appeal lies for penalty to CMD of said company. Now since that period is expired high court shall provide you appropriate remedy.
Rule 36.1- An appeal shall be preferred within one month from the date of communication
of the order appealed against. The appeal shall be presented to the Authority
specified in the schedule to whom the appeal lies, a copy being forwarded
by the appelant to the Authority which made the order appealed against. The
latter Authority, on receipt of the copy of the appeal, shall forward the same
together with its comments and the records of the case to the Appellate
Authority within 15 days without waiting for any direction from the Appellate
Authority. The Appellate Authority shall consider whether the findings are
justified or whether the penalty is excessive or inadequate and pass
appropriate orders within three months of the date of appeal. The Appellate
Authority may pass order confirming, enhancing, reducing or setting aside
the penalty or remitting the case to the Authority which imposed the penalty
or to any other Authority with such direction as it may deem fit in the
circumstances of the cas