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.
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.
What "fixing it" actually involves
- Pull the right period. Schedule FA is reported for the relevant accounting period — for the US, the calendar year, not the Indian financial year. This trips up most self-filed corrections.
- Report the holdings and the account. The vested shares and the brokerage account itself, with initial value (vesting-date FMV), peak value during the period, and closing value.
- Check the income side too. If dividends were received, they belong in income — with the DTAA credit claimed via Form 67, which is a separate filing. See how Form 67 actually works.
- Check the form. Once Schedule FA applies, ITR-1 is not available — you need ITR-2 (or ITR-3 if you also have business income). If the original went in on ITR-1, the revision fixes that too.
- File the revised return complete, not just the missing schedule.
For the field-by-field mapping from your broker statement, see Schedule FA from your broker statement, line by line.
If the window has closed
For an older year where the revised-return window is gone, a revised return is simply not available. An updated return may be possible for certain periods, and there are disclosure routes specific to foreign assets. Those are case-specific and time-bound — worth raising early rather than waiting, because the options narrow with time, not widen.
What to send
Your filed return (ITR-V / acknowledgement), your Form 16 (Form 130 from FY 2026-27), and your broker statements — vesting, dividend and sale reports, plus Form 1042-S if issued. The revised return with a complete Schedule FA is prepared from those for your approval before filing.
For the full picture of how foreign RSUs are taxed and disclosed, see RSU, ESOP and foreign stock taxation for resident employees.