It is a common realisation, usually a few weeks after filing: the return went in, the salary and the TDS were right — and nobody disclosed the vested RSUs or the US brokerage account in Schedule FA.
The good news: it is fixable, and the window is open. The important part: fix it now, voluntarily, rather than after a query.
The deadline for AY 2026-27
| Return type | Deadline |
|---|---|
| Belated return (never filed) | 31 December 2026 |
| Revised return (filed, needs correcting) | 31 March 2027 |
In each case, or before the assessment is completed — whichever comes earlier. So if you have already filed and only need to add Schedule FA, you are in revised return territory and the window runs to 31 March 2027.
That window is longer than it used to be, and it is no longer free throughout. The Finance Act 2026 substituted Section 139(5) with effect from 1 March 2026 so that a revised return may be filed before the end of the relevant assessment year — 31 March 2027 for AY 2026-27, where the old provision cut off three months earlier. In the same breath it inserted Section 234-I, a fee for revising late in that window: ₹1,000 where total income does not exceed ₹5 lakh, and ₹5,000 in any other case.
Practitioners are reading the fee as biting on revisions filed after 31 December 2026. The section's own wording measures the trigger in months from the end of the relevant year, and that phrasing is not free from doubt, so confirm the cut-off before promising a client a free revision in the closing months. The practical point stands either way: revise early in the window and the fee does not arise at all.
A revised return replaces the original entirely — it is not an amendment or an add-on. So the revised return must be complete and correct in every respect, not just in the part you are fixing.
Why this is worth doing immediately
Schedule FA sits under the Black Money (Undisclosed Foreign Income and Assets) Act, not merely the Income-tax Act. Non-disclosure of a foreign asset can attract a penalty of ₹10 lakh per year of default and possible prosecution — independent of any tax actually due. (Foreign assets other than immovable property below ₹20 lakh are now outside that exposure, but disclosure is still the correct course.)
Read that asymmetry carefully. The tax on a handful of vested shares may be small or nil. The consequence of the omission is not scaled to the tax. That is exactly why "there was no income, so it didn't matter" is a bad reason to leave it.
There is also the practical reality: foreign-asset information reaches the department through international exchange of information. An omission is not invisible, and it does not age well. A voluntary correction made before any query is a materially better position than an explanation offered after one.