Circular No.16687/CI/2025, Dt. 01.08.2025

What the circular governs

Circular No.16687/CI/2025 of the Office of the Inspector General of Registration, Chennai, concerns cash payments recorded in documents presented for registration, particularly documents involving immovable property. It repeats the registration department's instruction that cash transactions above Rs.20,000 mentioned in registered documents must be reported to the Income Tax Department.

The circular follows a Supreme Court judgment concerning cash transactions. The judgment directs a jurisdictional Sub Registrar to inform the jurisdictional Income Tax Authority whenever a document presented for registration claims that Rs.2,00,000 or more was paid in cash as consideration for the conveyance of immovable property. The Income Tax Authority must follow due process before taking action.

Who may be affected

Circular No.16687/CI/2025 directly applies to registering officers, District Registrars and Deputy Inspectors General of Registration. It may also affect buyers, sellers and other parties whose registered documents state that more than Rs.20,000 was paid in cash.

Reporting does not itself establish a violation. The Supreme Court direction quoted in the circular says that the jurisdictional Income Tax Authority must verify the transaction and follow due process before taking action.

Key instructions to registration officials

Circular No.16687/CI/2025 requires the following steps:

• Registering officers must examine the payment recitals in documents and check whether any cash transaction above Rs.20,000 is mentioned.
• If such a cash transaction is mentioned, the registering officer must inform the Income Tax Department immediately after registration and provide a copy of the document.
• The reporting details must be scanned with the registered document as a link page for future reference.
• If an officer fails to report, or delays reporting, the concerned District Registrar must report the matter to the concerned Zonal Deputy Inspector General so that disciplinary proceedings can be initiated against the officer.
• District Registrars responsible for audit must check registered documents and verify that reporting was completed without delay or omission.
• District Registrars and Deputy Inspectors General must supervise compliance by registering authorities.

The Supreme Court judgment quoted in Circular No.16687/CI/2025 also states that failure by a registering authority to report a cash payment of Rs.2,00,000 or more for an immovable property transaction may be brought to the Chief Secretary for appropriate disciplinary action.