What happens if I filed my ITR without Schedule FA?

You can file a revised return under Section 139(5) until December 31 of the assessment year to add Schedule FA. If that window has closed, an updated return under Section 139(8A) may be an option. The Income Tax Department has been running an active CBDT compliance campaign sending SMS and email alerts to taxpayers identified via CRS and FATCA data sharing — if you have received one, act before the window closes. Consult a CA to confirm which return type applies to your situation.

Is there a minimum value threshold below which Schedule FA is not required?

No. There is no minimum value threshold for Schedule FA. Even a dormant foreign bank account with a near-zero balance must be disclosed. Note: Finance Bill 2026 has proposed a one-time scheme providing immunity from prosecution for certain small taxpayers with undisclosed non-immovable foreign assets below ₹20 lakh; but this does not eliminate the disclosure obligation itself, and the exact conditions are subject to CBDT notification. Consult a CA before relying on this exemption.

How to Report Foreign Assets in Your ITR: Schedule FA, FSI, TR, and Form 67

If you hold foreign stocks, ETFs, or a bank account abroad, your ITR involves four separate compliance instruments: Schedule FA, Schedule FSI, Schedule TR, and Form 67.

Filing them in the wrong order, or confusing one for another, is the most common reason global investors receive defective return notices from the Income Tax Department.

This guide explains what each instrument does, how they connect to each other, and the exact sequence to follow when filing.

What are Schedule FA, FSI, TR, and Form 67?
Who needs to file these?
The calendar year rule you cannot miss
The correct filing sequence
Step 1: File Form 67 before your ITR
Step 2: Fill Schedule FSI
Step 3: Fill Schedule TR
Step 4: Fill Schedule FA
Common mistakes
How Paasa helps

What are Schedule FA, FSI, TR, and Form 67?

These four instruments cover two completely different compliance obligations: what you own and what you earned.

	Purpose	Where it lives	Mandatory?
Schedule FA	Declare all foreign assets you hold	Inside your ITR	Yes, for every ROR with foreign assets, even if you earned nothing
Schedule FSI	Report income you earned from foreign sources	Inside your ITR	Yes, if you earned any foreign income
Schedule TR	Summarise the tax relief you are claiming on foreign income	Inside your ITR	Auto-populated from Schedule FSI
Form 67	Enable your Foreign Tax Credit claim	Separate filing, before your ITR	Only if you paid foreign tax and want to claim credit

The most important thing to understand upfront: Schedule FA and the other three are not interchangeable. Many investors file Schedule FSI and Form 67 correctly but skip Schedule FA because they assume reporting income is enough. It is not. Under the Black Money Act, 2015, you can face a penalty of ₹10 lakh per year for not disclosing an asset in Schedule FA, even if the income from it was correctly reported elsewhere.

Note: ITR-1 and ITR-4 do not contain Schedule FA, FSI, or TR. If you hold any foreign asset, you must file ITR-2 or ITR-3.

Who needs to file these?

Your obligation depends on your residential status, not your citizenship.

Resident and Ordinarily Resident (ROR): You must file Schedule FA for all foreign assets, Schedule FSI for all foreign income, and Form 67 if you paid foreign tax and want to claim credit.

Resident but Not Ordinarily Resident (RNOR): You are exempt from Schedule FA. You only need Schedule FSI if your foreign income is directly taxable in India; for instance, income received into an Indian bank account, or income from a business controlled from India. In practical terms, your foreign portfolio can remain in place during the RNOR window without triggering Schedule FA disclosure obligations. This is one of the reasons the RNOR period is the right time to restructure your global holdings before full ROR status begins.

Non-Resident (NRI): None of these schedules apply to you.

The calendar year rule you cannot miss

Your ITR follows the Indian Financial Year (April 1 to March 31). Schedule FA does not.

Schedule FA follows the calendar year: January 1 to December 31 of the year that ends within the relevant financial year.

For AY 2026-27 (FY 2025-26), Schedule FA requires you to report all foreign assets held at any point between 1 January 2025 and 31 December 2025, not between April 2025 and March 2026.

This matters in two specific situations:

A stock you bought in February 2025 must be reported even though it was before the financial year started.
A stock you sold in November 2025 must still be reported, with a closing value of zero.

Note: Schedule FSI, TR, and Form 67 follow the financial year (April to March). Only Schedule FA uses the calendar year.

The correct filing sequence

The order in which you file these instruments is not optional. Filing them out of sequence is the leading cause of Foreign Tax Credit (FTC) denials.

The correct order:

File Form 67 on the Income Tax e-filing portal
File your ITR (ITR-2 or ITR-3), filling in Schedule FSI, Schedule TR, and Schedule FA inside the return

Form 67 must already be on the system before you file your ITR. The ITR form asks you to enter your FTC claim details, and the Central Processing Centre (CPC) cross-checks these against the Form 67 on record. If Form 67 is not there when your ITR is processed, the credit is automatically denied, even if your numbers are perfectly correct.

Step 1: File Form 67 before your ITR

Form 67 is the mandatory statement for claiming Foreign Tax Credit (FTC) in India. It is filed online on the e-filing portal, separately from your ITR.

You need Form 67 if: You paid tax in a foreign country, via withholding or direct payment, and want to offset that against your Indian tax liability.

You do not need Form 67 if: No foreign tax was withheld. For example, if you sold US stocks or Ireland-domiciled UCITS ETFs, the US and Ireland do not levy capital gains tax on non-residents, so there is nothing to claim.

What to gather before filing Form 67:

Proof of foreign tax deducted: For US stocks, this is typically Form 1042-S issued by your broker showing the dividend and the tax withheld.
The SBI Telegraphic Transfer Buying Rate (TTBR) on the last day of the month before the tax was paid. Example: tax deducted on June 15 – use the SBI TTBR rate from May 31. See the Form 67 guide for a full walkthrough of currency conversion.
Income breakdown by type (dividends, interest, capital gains) and by country.

How much credit can you claim?

India uses the Ordinary Credit Method. The FTC you can claim is limited to the lower of:

(A) Actual foreign tax paid
(B) Indian tax payable on that same income

If (A) exceeds (B), the excess is permanently lost. It cannot be carried forward.

Deadline: File Form 67 before you file your ITR. The technical outer deadline is March 31 of the assessment year, but waiting until then is a risk. For non-audit individuals, file before July 31.

Step 2: Fill Schedule FSI: report your foreign income

Schedule FSI (Foreign Source Income) is where you report all income you earned from sources outside India: dividends, interest, capital gains, rent, or salary from a foreign employer.

For each income item, you need to enter:

Country of source and its ISD country code
Taxpayer Identification Number (TIN) in that country
Nature and head of income — for example, dividends from US stocks go under "Income from Other Sources"
Amount in INR converted using the SBI TTBR on the date the income was received or accrued
Tax paid in the foreign country on that income (column C)
Tax relief claimed in India (column D) — this must match your Form 67 exactly

This income flows directly into your main ITR computation and is taxed at normal Indian rates. It is not exempt or separately treated; the FTC you claim through Form 67 then offsets the Indian tax on it.

Note: Schedule FSI does not capture losses. Only positive income is reported here.

Step 3: Fill Schedule TR: confirm your tax relief

Schedule TR (Tax Relief) is a country-wise summary of the tax relief you are claiming. It is not independently filled: it is populated directly from the column D figures you entered in Schedule FSI.

For each country, Schedule TR shows:

Total foreign tax paid on income also taxable in India (from FSI column C)
Total tax relief claimed (from FSI column D)

The figures here must match Form 67 exactly. Always reconcile all three before filing.

Which section applies?

Section 90: If India has a DTAA with the foreign country (US, UK, Singapore, etc.)
Section 91: If no DTAA exists, India provides unilateral relief limited to the lower of the Indian and foreign tax rates on that income

Step 4: Fill Schedule FA: declare your foreign assets

Schedule FA (Foreign Assets) is the disclosure schedule for everything you own outside India. It runs on the calendar year (January to December) and covers ten asset categories across multiple tables.

What must be reported:

Foreign bank and depository accounts
Brokerage and custodial accounts holding foreign stocks, ETFs, or bonds
Direct equity and debt interests in foreign companies (including vested RSUs and ESOPs)
Immovable property abroad
Foreign insurance policies with a surrender value
Accounts where you have signing authority but are not the owner
Foreign trusts and other financial interests

If you hold RSUs, see the dedicated Schedule FA guide for RSU holders and the complete ITR filing guide for RSU holders.

For each asset, you must enter:

Name and address of the foreign institution, country code, and currency code
Date of acquisition
Initial investment value, peak value during the calendar year, and closing value as of December 31 — all in both foreign currency and INR
Gross income earned from the asset during the calendar year

Exchange rates for Schedule FA:

All values must use the SBI TTBR on specific dates:

Value	Exchange rate date to use
Initial investment	Date of acquisition
Peak value	Date when the peak occurred
Closing balance and income	December 31 of the calendar year

If December 31 falls on a Sunday or bank holiday, use the SBI TTBR of the immediately preceding working day.

Example

Suppose you hold US stocks through Paasa. In calendar year 2025, you received $200 in dividends from your US portfolio, with $50 withheld as US tax.

The 25% withholding rate applies because you filed Form W-8BEN with your broker, activating the India-US DTAA rate instead of the default 30%.

Step 1 – Form 67: You file Form 67 before your ITR. You enter the $50 withheld, converted to INR using the SBI TTBR on the last day of the month before each dividend payment. See the Form 67 guide for the full conversion walkthrough.

Step 2 – Schedule FSI: You report $200 in dividends (converted to INR) under "Income from Other Sources." You enter the US tax paid in column C and the FTC you are claiming in column D; limited to the lower of the US tax paid or your Indian tax on that dividend income.

Step 3 – Schedule TR: The column D figure from Schedule FSI flows into Schedule TR as a single row for the United States. You confirm it matches your Form 67.

Step 4 – Schedule FA: You report your brokerage account (Table A2) with the peak value and closing value of your entire portfolio as of December 31, 2025, in both USD and INR. You also report each stock holding individually in Table A3.

Note: Even though you correctly reported your dividend income in Schedule FSI, you still need Schedule FA to disclose the underlying stocks. These are two separate obligations under two different laws.

If you hold only UCITS ETFs and received no distributions, your filing is simpler. Accumulating UCITS ETFs do not pay out dividends, and Ireland does not tax capital gains for non-residents, so no foreign tax is withheld and Form 67 is not required. You also have no foreign income to report, so Schedule FSI and TR do not apply. You only need Schedule FA to disclose the holdings.

Common mistakes

Filing Form 67 after the ITR

The most frequent error. Even a correctly filed ITR cannot retroactively claim FTC if Form 67 was not already on the system when the return was processed.

Mismatching figures across Form 67, Schedule FSI, and Schedule TR

The CPC runs an automated cross-check. Any discrepancy, even a rounding difference, flags the return as defective.

Using the April-March period for Schedule FA

Schedule FA covers January to December. Reporting the wrong period means assets acquired in January-March are missed entirely.

Reporting income in Schedule FSI but skipping Schedule FA

Two different obligations. The Black Money Act does not grant an exemption from Schedule FA because income was reported elsewhere.

Using the wrong exchange rate

Form 67 uses SBI TTBR on the last day of the month before the tax payment date, as required by Rule 128. Schedule FA uses SBI TTBR on the actual date of each event: the acquisition date for the initial investment, the date the peak occurred, and December 31 for closing balances. These are two different date rules serving two different purposes. Mixing them up creates a mismatch that can trigger a defective return notice.

Filing ITR-1 or ITR-4 when you hold foreign assets

Neither form contains Schedule FA, FSI, or TR. Any foreign asset disclosure made through ITR-1 or ITR-4 is invalid.

How Paasa helps

Paasa is the platform used by global Indian investors, NRIs, and family offices to invest across US, UK, China, Singapore, Switzerland, and beyond.

Paasa's tax advisory service provides complete filing support, from calculating correct values and exchange rates to ensuring every schedule reconciles.

What documents does Paasa provide for tax filing?

At the end of the financial year, Paasa provides a ready-to-file tax package containing:

Capital Gains Report: A clear breakdown of Short-Term vs. Long-Term capital gains, calculated using the 24-month holding rule for unlisted shares.
Dividend and Interest Reports: Consolidated statements showing income earned and tax withheld abroad, making it straightforward to fill Schedule FSI.
Schedule FA Report: Peak value and closing value of your entire portfolio in INR, calculated using the mandatory SBI TT Buying Rates. You can copy-paste these numbers directly into your ITR.

If you invest in global equities and have questions around taxation, FEMA, LRS, or compliance, feel free to reach out to our team.

Frequently Asked Questions

Do I need to file all four, Schedule FA, FSI, TR, and Form 67, every year?

Not necessarily all four. Schedule FA is mandatory every year you hold foreign assets as an ROR, regardless of income. Schedule FSI and TR are required only if you earned foreign income. Form 67 is required only if you paid foreign tax and want to claim credit. Most investors with foreign stocks will need Schedule FA every year, Schedule FSI whenever they receive dividends or sell assets, and Form 67 only when foreign tax was withheld.

I sold my US stocks. Do I still need to report them in Schedule FA?

Yes. Any asset held for even a single day during the calendar year must be reported in Schedule FA. The closing value will be zero since you no longer hold the shares, but the row still needs to be filled.

I hold UCITS ETFs domiciled in Ireland. Do I need to file Form 67?

Generally no. Ireland does not impose capital gains tax on non-residents. Accumulating UCITS ETFs do not pay out dividends, so no foreign tax is withheld. If no foreign tax was withheld on any income during the year, Form 67 is not required. You still need to report the ETF holdings in Schedule FA.

How to Report Foreign Assets in Your ITR