CA K Sanjay BhargavChartered Accountant
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How a foreign bank account is valued under FAST-DS

CA K Sanjay Bhargav, Chartered Accountant, Bengaluru

Membership No. 250054 · DISA (ICAI)

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Short answer: a foreign bank account is valued at the sum of every deposit made into it from the date it was opened up to 31 March 2026 — not the closing balance, and not the peak. Two exclusions apply. The practical effect is that an account holding almost nothing today can carry a very large declared value.

This is the single most misread part of the scheme, and it is the reason people who glance at their balance reach the wrong conclusion about their exposure.

The basis, and why it is unusual

Most valuation rules ask what a thing is worth on a date. This one asks what went into it, across its whole life.

Take an account opened in 2016 that received a modest salary, paid rent and living costs out again, and sits close to empty now. The balance says one thing. The declared value is built from every credit over ten years, which will be a multiple of anything the account ever held at one time.

That is not a quirk to work around. It is the measure, and any planning that starts from the balance is starting from the wrong figure.

The two exclusions

Redeposits from the same account. Money withdrawn and then put back into the same account is excluded, so the same funds are not counted twice. On an account used for day-to-day living this exclusion does a great deal of work — gross credits over several years can be many times what ever genuinely belonged to you, and without it the basis would double- and triple-count the same money.

An earlier Black Money Act declaration. Where the account was previously declared under Chapter VI of the Black Money Act, 2015 and tax and penalty were charged on it, only deposits made since that declaration count. The earlier period is not reopened.

Both exclusions have to be evidenced from the statements, which is the practical work.

No 20% tolerance here

For assets other than a bank account, Rule 5(2) allows a variance of up to 20% between the declared fair market value and the value later determined, without that difference by itself rendering the declaration invalid for misrepresentation.

That tolerance does not extend to bank accounts. The logic is clear enough: a property or a holding of unlisted shares is valued by judgment, and judgment can reasonably differ. A bank account is valued by adding up a statement, and arithmetic is expected to be right.

So on a bank account there is no margin. The figure has to be correct, and Section 134(3) provides that a declaration is invalid if any material particular is found to be false at any stage — a phrase with no time limit attached to it.

Getting the statements is the real task

Start here, because it governs the timetable:

  • Statements from account opening to 31 March 2026. Most foreign banks will produce them, but older periods can take weeks and sometimes carry a fee.
  • Evidence of withdrawals that were later redeposited, to support that exclusion.
  • The earlier Black Money Act declaration and the order charging tax and penalty, if one exists.
  • Where the account is closed or the bank has merged, the successor institution's records — which take longer again.

Reconstructing from memory is not an option. The declaration has to be exact, and it stays challengeable indefinitely if it is not.

Where this sits in the scheme

The window closes on 31 December 2026 and no declaration can be filed after it. The valuation work above is the part that determines whether the timetable is comfortable or not — an account opened fifteen years ago at a bank that has since been acquired is not a two-week exercise.

The full scheme — eligibility, what it costs, the four-form sequence and the payment clock — is in FAST-DS 2026.

If the account is one you hold alongside vested shares on an employer platform, the worksheet below assembles the account and holding figures together — see also Schedule FA from your broker statement.

This is a working reference, not the statute. Confirm the valuation basis and the exclusions against the Rules before computing a declaration.

Download the Schedule FA peak balance worksheet

The month-by-month working that computes peak value for you, the account and holdings tables with the source for every field, and a pre-filing checklist. CSV — opens in Excel or Google Sheets.

Your number is used to answer questions on the worksheet and on foreign asset reporting. No third-party sharing, and you can ask to be removed at any time.

Frequently asked questions

Is it the closing balance?

No. Neither the closing balance nor the peak balance. The value is the sum of every deposit made into the account from the date it was opened up to 31 March 2026. That is a cumulative figure over the life of the account, not a snapshot of it.

So an account with almost nothing in it can still have a large value?

Yes, and that is the single most important consequence of the deposit basis. An account that received salary for six years and was drawn down to near zero carries a declared value built from all six years of credits. People who check the balance and conclude the exposure is small are reading the wrong number.

What if I moved the same money in and out repeatedly?

Redeposits of money withdrawn from the same account are excluded, so the same funds are not counted twice. That exclusion matters enormously on an account used for day-to-day living, where the gross credits over several years can be many times what ever actually belonged to you.

I declared this account under the Black Money Act years ago. Does it all count again?

No. Where the account was earlier declared under Chapter VI of the Black Money Act, 2015 and tax and penalty were charged on it, only deposits made since that declaration are counted. The earlier period is not brought back in.

Does the 20% valuation tolerance apply to bank accounts?

No, and this is a distinction worth being precise about. Rule 5(2) allows a variance of up to 20% between the declared fair market value and the value later determined, for assets other than a bank account, without that difference by itself invalidating the declaration. It expressly does not extend to bank accounts — because a bank account is valued by arithmetic on a statement rather than by judgment, and arithmetic is expected to be exact.

What if I cannot get statements going back to when the account was opened?

Then that is the first problem to solve, and it takes longer than people expect. Most foreign banks will produce historical statements on request, though older periods can take weeks and sometimes carry a fee. Reconstructing from memory is not an option here: the declaration has to be exact, and Section 134(3) makes a declaration invalid if any material particular in it is found to be false at any stage.

What date are the assets valued at?

31 March 2026, fixed by the Rules. For a bank account the deposit run therefore ends on that date; for other asset classes the prescribed method differs, and a valuation report is uploaded with the declaration where one is required.

Working out what an old account would declare at?

Send the statement history for the account and the years involved. What the declared value actually comes to under the deposit basis — and whether either exclusion applies to you — is computed before anything is filed.

Related service: Foreign Income / RSU & ESOP