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Knowledge Bank / Income-tax Act, 2025 / Chapter VI - AGGREGATION OF INCOME

Section 106

Section 106: amount borrowed or repaid through negotiable instrument, hundi, etc

Section 106 targets loans borrowed or repaid outside the account-payee-cheque banking channel - for example, through a hundi or other negotiable instrument, or any other mode the Board specifies. Such amounts (including interest) are deemed to be income of the person borrowing or repaying, in the year the borrowing or repayment happened.

This explanation is AI-assisted and pending review by our CA/CS team. It is general information, not professional advice - always cross-check against the bare law text above or talk to our tax team for guidance specific to your situation.

What Section 106 says

Where any amount, including interest on it, is borrowed or repaid through a negotiable instrument or hundi - other than by an account payee cheque - or through any other mode the Board specifies, the amount so borrowed or repaid (including any interest paid on the borrowed amount) is deemed to be the income of the person borrowing or repaying it, for the tax year in which the amount was borrowed or repaid.

No double taxation on repayment

Where the borrowed amount has already been deemed to be a person's income under sub-section (1), that person is not assessed again on the same amount under this sub-section when it is later repaid.

Frequently asked questions

What kind of borrowing does Section 106 target?

Amounts borrowed or repaid through a negotiable instrument or hundi (rather than an account payee cheque), or through any other mode specified by the Board.

Is the same amount taxed twice, once on borrowing and once on repayment?

No - once an amount has been deemed income on borrowing, it is not assessed again under Section 106 when it is repaid.

Related sections

  • Section 102 - unexplained credits
  • Section 107 - how unexplained income is taxed

Want this applied to your actual filing, not just explained?

Get help responding to a cash loan/hundi query

Last updated 9 September 2026

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