CA K Sanjay BhargavChartered Accountant
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The income tax email about overseas financial interests: what it is and what to do

CA K Sanjay Bhargav, Chartered Accountant, Bengaluru

Membership No. 250054 · DISA (ICAI)

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Short answer: the email is an information message, not a notice. It is built from data foreign tax authorities send India under the automatic exchange of information framework, which you can now see in your Annual Information Statement (AIS) under Reports → Foreign Assets Information. What you do next depends on one question: was every foreign asset in Schedule FA of every return for the years shown? If yes, there is nothing to regularise. If the gap is in the AY 2026-27 return, revise it by 31 March 2027. If it is in an earlier year, the FAST-DS window closes on 31 December 2026.

What the email says

From about 24 September 2026 the Income Tax Department has been sending taxpayers an email that opens:

"Our records indicate that you may have overseas financial interests (such as bank accounts, shares, or immovable property etc.) acquired in earlier years, that are required to be reported in Income Tax Return."

It goes on to name the Foreign Assets of Small Taxpayers – Disclosure Scheme, 2026 (FAST-DS), says declarations are open until 31 December 2026, and points to the Foreign Assets Information on the AIS through the e-filing portal. It also mentions Kar Saathi, the AI assistant the department launched on 2 April 2026 on its e-filing portal.

Three things the email is not:

  • It is not a notice. It does not cite a section of the Income-tax Act or of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (the Black Money Act). It raises no demand and opens no assessment.
  • It does not ask for a reply or set a date to respond by.
  • It is not a finding. It says you may have foreign interests. Whether anything is missing from your returns is a separate question, and often the answer is no.

Do not act on links in any email claiming to be from the department; go to the e-filing portal directly and log in there.

Kar Saathi answers general questions, such as which return form to use and how Schedule FA works. It gives guidance, not a view on your facts, and does not replace reading your filed returns against the AIS data.

Where the data comes from

India receives financial account information on its tax residents from more than 100 jurisdictions under the Common Reporting Standard (CRS), and from the United States under its FATCA agreement with India. Each year's data, which covers the preceding calendar year, starts arriving in September.

The Central Board of Direct Taxes (CBDT) ordered on 8 July 2026, under section 119 of the Income-tax Act 1961, that this data be displayed in each taxpayer's AIS. The display went live in July. CBDT's own note describes it as a facilitation measure rather than an investigation tool, and says that data for calendar years 2022, 2023 and 2024 is shown now, with 2025 to follow once received in September or October 2026.

This is not the first campaign on the same data:

WhenWhat it covered
17 November 2024First NUDGE campaign: SMS and emails on AY 2024-25 returns
28 November 2025Second NUDGE campaign: AY 2025-26 returns, revise by 31 December 2025
July 2026Emails on reporting foreign assets in AY 2026-27 returns, alongside the AIS display
From about 24 September 2026This email, naming FAST-DS and the 31 December 2026 deadline

The difference this time is that the email points to a way of settling earlier years.

Step one: open Foreign Assets Information in your AIS

This is the path CBDT itself published:

  1. Log in at the e-filing portal (eportal.incometax.gov.in).
  2. Click AIS. You are taken to the Compliance Portal.
  3. Click Reports, then the Foreign Assets Information tab.
  4. Choose the calendar year from the drop-down and click Download PDF.
  5. Open the PDF with your PAN in lower case followed by your date of birth as ddmmyyyy.

The report is set out country by country. For each account it shows the reporting institution, the account number, the currency, and amounts under four heads (dividend, interest, gross proceeds and other payments), plus the account balance.

Map each calendar year to the return it belongs to. Schedule FA is reported by calendar year, not the Indian April-to-March year:

Calendar year in AISSchedule FA in the return forRevised return still possible?
2022AY 2023-24No
2023AY 2024-25No
2024AY 2025-26No, the window closed on 31 December 2025
2025 (expected Sept–Oct 2026)AY 2026-27Yes, until 31 March 2027

Two limits on what the report tells you. First, CBDT says in terms that the data is not a complete record, and that Schedule FA must report everything whether or not it appears in AIS. Second, what the US sends India under FATCA is narrower than CRS data: interest on deposit accounts and US-source dividends and other income, not account balances. A US brokerage account holding RSUs that paid no dividend in the year may not appear at all. Absence from AIS is not permission to leave something out.

What to do, by situation

Your situationWhat it meansWhat to do
(a) Every asset was in Schedule FA for every year, and the income on it was taxedNothing to regulariseNothing, unless an AIS entry is actually wrong; then use AIS feedback
(b) Something was left out of the AY 2026-27 return you filed this yearStill curable by revisionFile a revised return by 31 March 2027
(c) Something was left out in AY 2025-26 or earlierRevised-return window closedFAST-DS by 31 December 2026, or check whether the ₹20 lakh threshold removes the penalty exposure
(d) The data is not yours, or the account was closed before the year shownA data problem, not a disclosure problemAIS feedback
(e) You are non-resident nowYour resident years may still be openCheck those years; FAST-DS is available to you

(a) Everything was reported

If each foreign account and holding appears in Schedule FA for each relevant year, and the interest, dividends and sale gains were offered to tax, there is nothing to regularise. Mismatches between the AIS figures and your Schedule FA are expected, because CRS reports the year-end balance while Schedule FA asks for peak and closing values, converted at SBI's telegraphic transfer buying rate on specified dates.

You may confirm entries through the feedback option, but you do not have to. If you do, be sure first: CBDT's screens warn that feedback cannot be modified once submitted.

(b) The gap is in this year's return

For AY 2026-27 a revised return under section 139(5) can be filed until 31 March 2027, or before assessment is completed if that is earlier. Revising early matters: section 234-I charges a fee of ₹1,000 (total income up to ₹5 lakh) or ₹5,000 (above that) on revisions filed late in the window, read by practitioners as after 31 December 2026.

A revised return under section 139(5) is one of the returns that the Black Money Act's reporting penalty looks at, so revising cures the Schedule FA omission for that year. The mechanics are in missed Schedule FA? The revised return window.

(c) The gap is in an earlier year

For AY 2025-26 and earlier, a revised return is no longer available. An updated return (ITR-U) can bring the missed income to tax, but it does not cure the Schedule FA omission, because it is not a return that the Black Money Act's reporting penalty refers to. How the two routes compare is in revised return, ITR-U or FAST-DS.

FAST-DS is the route that settles the Schedule FA default itself. It is at sections 130 to 144 of the Finance Act, 2026, and its Table has two entries:

Entry 1Entry 2
ForA foreign asset with no explained source, or foreign income never taxedAn asset funded from income earned while non-resident, or from income already taxed in India, but left out of Schedule FA
Cost30% of the asset's value at 31 March 2026, plus 30% of the income, plus 100% of that tax (60% where only an asset is declared)Flat ₹1,00,000
CeilingAggregate ≤ ₹1 croreAsset value ≤ ₹5 crore

Both ceilings are cliffs rather than bands; see the ₹5 crore cliff. A foreign bank account is valued at the sum of every deposit since it was opened, not the balance, which catches many people out; see how a foreign bank account is valued. The declaration is Form 1-FADS26, live on the portal since 1 September 2026, and the four-form sequence behind it is in filing the declaration. The full scheme is in the FAST-DS pillar.

Before declaring, check the threshold. From 1 October 2024 the penalty for failing to report foreign assets does not apply where the aggregate value of those assets, other than immovable property, does not exceed ₹20 lakh, and a CBDT instruction of 18 August 2025 says prosecution will not be started in those cases either. Whether that reaches defaults before 1 October 2024 is arguable. The detail is in the ₹20 lakh threshold.

(d) The data is wrong

Use the Submit Feedback option on the Foreign Assets Information tab. You pick the entry by its TSN (the reference number shown against it), choose a feedback type and what the feedback is for, and add remarks of up to 400 characters. The department's user guide lists the feedback types as information is correct, does not pertain to me, is partially correct, and is incorrect. Feedback can be given only once for each category, so get the wording right before submitting, and download the acknowledgement from Activity History promptly: the guide says receipts are kept there for 10 days. How to word it is in AIS Foreign Assets Information feedback.

Two cases that look like data errors but are not:

  • A joint account is yours. CRS usually reports the full balance against each holder, and each resident holder reports the account in Schedule FA. It is not a "does not pertain to me" case.
  • An account closed during the year is still reportable for that year. Schedule FA covers assets held at any time in the calendar year. Only an account closed before the year shown is a genuine error.

(e) You are non-resident now

Schedule FA is filled only by a resident and ordinarily resident individual, so non-resident years carry no Schedule FA obligation. The email may still be about years when you were resident. It can also be triggered by an old tax-residence self-certification with a foreign bank that still gives an Indian address. FAST-DS allows a person who is non-resident today to declare if they were resident when the income arose or the asset was acquired; see can an NRI use FAST-DS.

What happens if you do nothing

Nothing follows from the email itself. What matters is whether there is an omission underneath it. Where there is, these are the provisions of the Black Money Act, stated plainly:

ProvisionWhat it does
Section 3Tax at 30% on the value of an undisclosed foreign asset, one whose source you cannot explain, valued in the year it comes to the Assessing Officer's notice
Section 41Penalty of three times that tax, so 120% of value in all
Section 43Penalty of ₹10 lakh for failing to report a foreign asset or foreign income in a return, even where the money was taxed
Section 50Prosecution for that failure: rigorous imprisonment of 6 months to 7 years, with fine
Section 51Prosecution for wilful attempt to evade tax: 3 to 10 years, with fine

Section 43 is worded as a penalty the officer may impose, and it is subject to the ₹20 lakh proviso above. Because an undisclosed asset is valued when it comes to notice, not when it was acquired, the charge does not fall away with time.

The other fact is the date. FAST-DS closes on 31 December 2026. The date sits in the Rules and could in principle be moved by notification, but no extension has been announced. After it, what remains is the full Black Money Act position and whatever defence the facts support.

What to gather this week

Most of the time goes on collecting documents, not filing forms:

  1. The Foreign Assets Information PDF for each calendar year shown in AIS, and again once 2025 data appears.
  2. Statements for every foreign bank account since it was opened, not just recent ones. FAST-DS values an account on total deposits since opening, and old statements from an overseas bank can take weeks.
  3. Broker and equity-plan statements: vesting, release, sale and dividend reports, account statements for each calendar year, and Form 1042-S where issued.
  4. Every return filed for the years involved, as filed, including Schedule FA and Schedule FSI (foreign source income).
  5. Form 16 for the years RSUs or ESPP shares vested, which shows the shares were taxed as salary. That is what places an asset in Entry 2 rather than Entry 1.
  6. Your residential status for each year: passport stamps or travel records giving days in India. It decides whether Schedule FA applied and which FAST-DS entry is open.

With those in hand, the table above can be worked through quickly. If you are not sure what counts, the foreign assets people forget to report goes through the usual misses.

For how RSUs, ESPPs and foreign brokerage accounts are taxed and reported year to year, see foreign income, RSU and ESOP filing.


This note explains the September 2026 foreign-asset emails and the routes open to someone who receives one. It is not advice on any individual's position. The email's wording is taken from copies received by taxpayers; the AIS navigation and data coverage are from CBDT's published note on the Foreign Assets Information display. The FAST-DS figures are from sections 130 to 144 of the Finance Act, 2026 and the FADS Rules 2026. Which situation applies turns on your returns, your residential status by year and the source of each asset's funding, and those should be confirmed before a revised return or declaration is filed.

Frequently asked questions

Is the email about overseas financial interests a tax notice?

No. It does not cite a section of the Income-tax Act or the Black Money Act, it does not raise a demand, and it does not start an assessment. It is an information message built from data that foreign tax authorities send India under the automatic exchange of information framework. CBDT has described the underlying AIS display as a facilitation measure rather than an investigation tool. That said, the data behind it is the same data the department can use later, so the email is a good reason to check your returns now rather than something to file away.

Do I have to reply to the email?

The email itself does not ask for a reply or set a date to respond by. What it asks is that you check the Foreign Assets Information in your Annual Information Statement and consider whether your returns reported everything. If an entry in that report is wrong, the response goes through the feedback option inside AIS, not by answering the email. If something was genuinely left out of Schedule FA, the response is a revised return or a FAST-DS declaration, depending on the year.

Where do I see what the department has on me?

Log in to the e-filing portal and open AIS, which takes you to the Compliance Portal. Click Reports, then Foreign Assets Information, choose the calendar year from the drop-down and download the PDF. The file is password-protected with your PAN in lower case followed by your date of birth as ddmmyyyy. Calendar years 2022, 2023 and 2024 are shown now; CBDT said 2025 data would follow once received in September or October 2026.

I reported everything in Schedule FA. Why did I get the email?

The emails are sent on the basis of the foreign data received, and matching it against returns is not perfect. Common reasons are a calendar-year mismatch, an account reported under a different number or institution name, or a joint account. If every foreign asset was in Schedule FA for each year and the income on it was taxed, there is nothing to regularise. You may confirm the entries in AIS, but feedback cannot be edited once submitted, so do it only after checking.

What happens if I ignore it?

Nothing follows from the email itself. The exposure comes from the underlying omission, if there is one. Under the Black Money Act an unexplained foreign asset is taxed at 30% of its value with a penalty of three times that tax, failing to report a foreign asset in a return carries a penalty of ₹10 lakh, and prosecution provisions exist for both. FAST-DS, which settles those defaults for less and grants immunity, closes on 31 December 2026 and cannot be used after that.

I live abroad now. Does any of this apply to me?

Possibly, for the years you were resident. Schedule FA is filled only by a resident and ordinarily resident individual, so years in which you were non-resident or not ordinarily resident carry no Schedule FA obligation. But an account opened or funded while you were resident in India, and never reported in those years, is still an open default. FAST-DS expressly allows a person who is non-resident now to declare if they were resident in the year the income arose or the asset was acquired.

Got the email and not sure which situation you are in?

Send the email, the Foreign Assets Information PDFs from your AIS and the returns filed for the years shown, on WhatsApp or by email. Whether anything is actually missing, and whether the fix is a revised return, FAST-DS or nothing at all, is worked out before anything is filed.

Related service: Foreign Income / RSU & ESOP