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Clause 30 of Form 3CD — Hundi Borrowings Under Section 69D

Clause 30 reports amounts borrowed on hundi, and amounts due on them including interest, repaid otherwise than through an account payee cheque — the section 69D charge, explained...

Published
Updated
Reading time
6 min
Questions
6 answered
  • High Complexity
Topic
Income Tax
Published
September 8, 2026
Last updated
Sep 8, 2026
Reading time
6 min
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Last updated: September 2026Verified against: Government sources
Which year this governs

From the ICAI Guidance Note on Tax Audit (Revised 2026), the Eleventh and concluding edition under the Income-tax Act, 1961. For tax years under the Income-tax Act, 2025 the corresponding provision must be identified afresh, and the particulars move to Form No. 26 under rule 47 of the Income-tax Rules, 2026.

What the clause asks

"Details of any amount borrowed on hundi or any amount due thereon (including interest on the amount borrowed) repaid, otherwise than through an account payee cheque. "

Paragraph 51.1: details of the amount borrowed on hundi (including interest on such amount borrowed) and details of repayment of such borrowings otherwise than by an account payee cheque are required to be indicated. A reference may also be made to Circular No. 208 dated 15 November 1976 and Circular No. 221 dated 6 June 1977 issued by the Board explaining the provisions of section 69D — both reproduced at Appendix XX to the Guidance Note.

Both legs are caught, not only the repayment

Section 69D operates on borrowing on a hundi otherwise than through an account payee cheque as well as on repayment of the amount due, including interest, by any other means. The clause heading emphasises repayment, but paragraph 51.2 asks the auditor for a complete list of borrowings and repayments. A hundi taken in cash and repaid by account payee cheque is still within the section's reach.

What the auditor does

Paragraph 51.2, on completing clause 30: the tax auditor should obtain a complete list of borrowings and repayments of hundi loans otherwise than by account payee cheques and verify the same with the books of account.

Paragraph 51.3 acknowledges the limit of that verification honestly: there will be practical difficulties in verifying the loan taken or repaid on hundi by account payee cheque. In such cases the tax auditor should:

  • verify the borrowing and repayments with reference to such evidence as may be available; and
  • in the absence of conclusive or satisfactory evidence, obtain a suitable certificate or management representation in this regard.

The pattern is the same as at clause 21(d), where paragraph 36.4 permits reliance on a certificate about payment modes because the bank statement cannot answer the question. The discipline that goes with it is also the same: where the reporting rests on a certificate, the fact should be stated as an observation in Para 3 of Form 3CA or Para 5 of Form 3CB — the omission the TAQRB found at clause 21(d).

The clause 30 working paper

Paragraph 51.4 recommends this format, matching the e-filing utility:

ColumnContent
(b)Name of the person from whom the amount was borrowed, or repaid, on hundi
(c)PAN of that person, if available
(d)Address of that person, with city, state and PIN code
(e)Amount borrowed during the previous year
(f)Date of borrowing
(g)Amount due including interest
(h)Amount repaid including interest during the previous year
(i)Date of repayment

Two things follow from the column list. The reporting is party-wise and transaction-wise, with dates — the same granularity the TAQRB insisted on at clauses 21(b) and 23. And the address with city, state and PIN code is required, not just a name — the level of detail that makes an incomplete-payee-particulars finding easy to make.

Where this sits among the cash-transaction clauses

ClauseProvisionWhat it catches
21(d)Sections 40A(3) and 40A(3A)Expenditure paid in cash above Rs 10,000 or Rs 35,000
Clause 30Section 69DHundi borrowings and repayments, including interest, otherwise than through an account payee cheque
31(a) to (e)Sections 269SS, 269ST and 269TLoans, deposits, specified sums and specified receipts outside the prescribed modes

The three clauses overlap in subject but not in scope. A hundi is a specific instrument, and section 69D applies to it whatever the amount — there is no monetary threshold of the kind sections 40A(3) and 269SS carry. That is why the clause 30 population has to be identified by instrument type, from the loan documentation, rather than by scanning the cash book for large amounts. A small hundi transaction is as reportable at clause 30 as a large one.

Worked example

TransactionReporting
Rs 4,00,000 borrowed on a hundi in cash on 12 JuneReport the borrowing with date, name, PAN and full address
Rs 4,32,000 including interest repaid in cash on 20 JanuaryReport the repayment with the amount due including interest and the date
Rs 2,00,000 borrowed on a hundi by account payee cheque, repaid in cashReport the repayment
An ordinary unsecured loan in cash, not on a hundiNot clause 30 — test under sections 269SS and 269T at clause 31
Hundi transactions where the mode cannot be established from the recordsVerify against available evidence; obtain a certificate or management representation, and state that reliance as an observation

Audit checklist

  • Identify hundi transactions by instrument type from the loan documentation, not by amount.
  • Obtain a complete list of borrowings and repayments otherwise than by account payee cheque, and verify against the books.
  • Include interest in the amount due and the amount repaid.
  • Capture name, PAN and full address with city, state and PIN code for each party.
  • Record dates of borrowing and of repayment.
  • Where evidence is inconclusive, obtain a certificate or management representation and disclose that reliance in the report.
  • Read Circulars No. 208 of 1976 and No. 221 of 1977 at Appendix XX.

Common mistakes

  • Reporting only repayments and omitting the borrowings.
  • Excluding interest from the amounts reported.
  • Applying a monetary threshold — section 69D has none.
  • Giving a name without the PAN and full address.
  • Relying on a management representation without disclosing that reliance in the report.
Quick recapKey facts & short answers

Key Facts About Clause 30

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What does clause 30 require?

Details of any amount borrowed on hundi, or any amount due thereon including interest on the amount borrowed, repaid otherwise than through an account payee cheque, under section 69D.

Which circulars explain section 69D?

Circular No. 208 dated 15 November 1976 and Circular No. 221 dated 6 June 1977, reproduced at Appendix XX to the Guidance Note.

A deduction without the document behind it is only a hope.

— TaxClue Direct Tax Desk

Clause 30: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

Details of any amount borrowed on hundi, or any amount due thereon including interest on the amount borrowed, repaid otherwise than through an account payee cheque, under section 69D.

Circular No. 208 dated 15 November 1976 and Circular No. 221 dated 6 June 1977, reproduced at Appendix XX to the Guidance Note.

A complete list of borrowings and repayments of hundi loans otherwise than by account payee cheques, verified against the books of account.

There will be practical difficulties in verifying whether a hundi loan was taken or repaid by account payee cheque; the auditor should verify against such evidence as is available and, in the absence of conclusive or satisfactory evidence, may obtain a suitable certificate or management representation.

Yes. The clause covers the amount borrowed on hundi including interest on such amount borrowed, and the details of repayment of such borrowings otherwise than by an account payee cheque.

Name, PAN and address of the person from whom borrowed or to whom repaid, amount borrowed during the year, date of borrowing, amount due including interest, amount repaid including interest, and date of repayment.