Official guidance, Tamil Nadu land law
Circular No. 16687/CI/2025, dated 1 August 2025
The Office of the Inspector General of Registration, Chennai, issued Circular No. 16687/CI/2025 dated 1 August 2025, directing registering officers to report cash transactions above Rs. 20,000 recorded in registered documents to the Income Tax Department. The circular also requires immediate reporting after registration, retention of reporting details with the document, audit monitoring and disciplinary action for failures or delays.
What the circular governs
Circular No. 16687/CI/2025 dated 1 August 2025 was issued by the Office of the Inspector General of Registration, Chennai. It gives instructions to registering officers on identifying and reporting cash payments recorded in documents presented for registration. A copy was also sent to the Additional Chief Secretary to Government, Commercial Taxes and Registration Department.
The circular refers to earlier instructions issued by the Inspector General of Registration and to the judgment of the Supreme Court of India in Civil Appeal No. 5200 of 2025 arising from SLP (C) No. 13679 of 2022.
What registering officers must do
Circular No. 16687/CI/2025 requires registering officers to:
- Examine document recitals and payment details to identify any cash transaction above Rs. 20,000.
- Inform the Income Tax Department immediately when such a cash transaction is recorded.
- Send a copy of the document to the Income Tax Department after registration.
- Scan the reporting details with the registered document as a link page for future reference.
- Follow the instructions strictly and avoid delay in reporting.
Supreme Court direction referred to
The Supreme Court judgment quoted in Circular No. 16687/CI/2025 addresses claims involving cash payments of Rs. 2,00,000 and above. For an immovable property conveyance presented for registration, the judgment directs the jurisdictional Sub-Registrar to inform the jurisdictional Income Tax Authority when the document claims that Rs. 2,00,000 or more was paid in cash as consideration.
The Income Tax Authority must then follow due process before taking action. The judgment also provides for the registering authority's failure to report such a transaction to be brought to the Chief Secretary for disciplinary action.
Who may be affected
Circular No. 16687/CI/2025 may affect buyers, sellers and others whose registered documents record cash payments above Rs. 20,000. The circular does not state that registration must be refused. It requires the transaction to be reported after registration.
District Registrars responsible for audit must check compliance and delays. District Registrars and Deputy Inspectors General of Registration must supervise registering authorities, and failures may lead to disciplinary proceedings against the responsible officials.
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Common questions
Will a cash payment above Rs. 20,000 in my property document be reported?
Yes. Circular No. 16687/CI/2025 directs registering officers to report cash transactions above Rs. 20,000 mentioned in documents to the Income Tax Department after registration.
Does the circular say that my document will be refused registration?
No. The circular requires reporting after registration and does not state that registration must be refused.
What happens when Rs. 2,00,000 or more is shown as cash consideration for immovable property?
The Supreme Court direction quoted in the circular requires the jurisdictional Sub-Registrar to inform the jurisdictional Income Tax Authority. The authority must follow due process before taking action.
How is the report kept with the registered document?
The registering officer must scan the reporting details with the document as a link page for future reference.
