A foreign account in your AIS: a gap, or a false alarm?

Summary

A line in the Foreign Assets Information report of your AIS is not a finding that you did anything wrong: Schedule FA applies only in a year you were resident and ordinarily resident, and several kinds of line are false alarms. Read each line against six facts before choosing a fix, because feedback on the portal cannot be changed once submitted.

The situation

Since 24 July 2026 the department has been sending SMS and e-mail telling taxpayers that information on their foreign accounts has arrived under the automatic exchange agreements and reminding them to report foreign assets for AY 2026-27. The AIS now carries one line per foreign account per calendar year for 2022, 2023 and 2024; CBDT's press release of 16 July says calendar-2025 data will be displayed once received in September or October 2026.

The people forwarding these screenshots to me are mostly returned NRIs and employees holding US stock. The first question they ask is how to fix it. The better first question is whether there is anything to fix.

The rule

What the line is. CBDT's note on the display of CRS and FATCA data (the annexure to its OM of 17 July 2026) sets out the report: grouped by country, one row per account with a transaction sequence number (TSN), the institution, the account number, the reporting currency, then A Dividend, B Interest, C Gross Proceeds, D Any Other Payments, an INR total, and the account balance. It is downloaded from the Compliance Portal under Reports, Foreign Assets Information, as a password-protected PDF (PAN in lower case plus date of birth as ddmmyyyy).

Who must report. Schedule FA comes from the fourth proviso to section 139(1) of the Income-tax Act, 1961, which applies to "a person, being a resident other than not ordinarily resident in India". A non-resident or an RNOR has no Schedule FA duty for that year. Schedule FA runs on the calendar year, so each AIS year maps to one assessment year:

An account held on any day of that calendar year is reportable for it. All four are 1961-Act years. From tax year 2026-27 the same duty sits under section 263 of the Income-tax Act, 2025 (the old section 139).

What omission costs. Section 43 of the Black Money Act, 2015 imposes ₹10,00,000 per return where a resident and ordinarily resident omits a foreign asset from Schedule FA, whether or not its source is explained. A proviso inserted by the Finance (No. 2) Act, 2024 from 1 October 2024 removes that penalty where the aggregate value of the foreign assets other than immovable property does not exceed ₹20,00,000. Whether that proviso reaches omissions before October 2024 (the CY2022 and CY2023 returns), and how non-bank assets are valued for it, are both contested.

CBDT's own framing. The display is "to facilitate, and not to investigate"; the AIS "does not constitute a complete or exhaustive record"; and the Schedule FA duty stands "irrespective of whether such assets or income are reflected in AIS".

Where people go wrong

Treating the line as the verdict. For each line, six facts decide it: the calendar year, your status in that year, whether you already reported the account, whether the line is really yours and really one account, where the money came from, and whether the income was taxed. A returned NRI who was RNOR for FY 2022-23 has a CY2022 line and no CY2022 gap.

Reading Gross Proceeds as income. Column C is the total sale value on a custodial (broker) account. A ₹40 lakh figure there may be ₹2 lakh of gain. The taxable amount is the gain; the balance and income columns are what Schedule FA asks for.

Missing the patterns that are not gaps at all. A line that belongs to someone else. An account closed before 1 January of that year. The same account under two TSNs. A nominal joint holder who put in no money (a Tribunal-level defence, not a certainty). Two lines at one broker for a custody account and a depository account are two accounts, not a double count. And the reverse trap: an account closed in March is still reportable for that year.

Submitting feedback in a hurry. Feedback is given per TSN with a type, a "for" field and a 400-character remark, and the annexure says "Feedback once submitted will not be modified." Decide the line first.

Assuming the updated return is open. Section 139(8A) of the 1961 Act (section 263(6) of the 2025 Act) bars an updated return where information received under a tax treaty or exchange agreement has been communicated to you before you file. Whether the AIS line or the SMS is such a communication has not been settled by any authority I have found. Ask before you rely on that route.

Answering the wrong message. A phishing e-mail copying the department's nudge, with a 72-hour threat and no DIN, has circulated since early September. Check any message through the portal's Authenticate Notice/Order or the AIS "Authenticate Insight DIN" facility. A genuine notice carrying a section and a date is a different event from the awareness SMS, and belongs with your CA the same day.

What to do

1. Download the Foreign Assets Information report for each calendar year shown and list every line by TSN.
2. Fix your residential status for each matching financial year from your travel dates; for any year you were NR or RNOR, the line needs no Schedule FA fix.
3. Mark each remaining line as yours or not, open or closed before 1 January, and single or duplicate, and read balance and income, never gross proceeds, as the reportable figures.
4. For each year with a real gap, total all non-immovable foreign assets, including those not in AIS, and see where you fall against ₹20,00,000.
5. Only then choose the route and give portal feedback, line by line, with a remark you would be content to see quoted back to you. If a year is a real gap and the source is in doubt, the FAST-DS category is a separate question: [FAST-DS route check](Open the fast ds route check page).

The tool

I kept doing this triage in a notepad, one line at a time, for clients who had received the SMS, so I built a page for it. You type each line from the report and answer six questions for it, and it tells you, per line and per calendar year, whether the line is a gap or a false alarm and why, runs the ₹20 lakh test on the values you enter plus any foreign assets the AIS does not show (saying plainly where that test is contested), names the routes with their dates, and prints a triage note for the file. It does not compute your residential status (it asks you for it), does not convert currencies or value anything, and does not settle whether the department's message has closed the updated-return door; treat that route as a question for your CA. Nothing you type is stored.

Open the aeoi line triage page

Sources

1. CBDT — Display of CRS/FATCA information in AIS (annexure to OM F.No. 414(B)/21/2023-IT(Inv.VI)/64, 17 July 2026) — https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-07/Annexure.pdf
2. Income-tax Act, 1961 — section 139 (fourth proviso to sub-section (1); sub-section (8A)) — https://www.incometaxindia.gov.in/w/section-139-63
3. CBDT OM of 17 July 2026 (hosting of the note on CRS in AIS) — https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-07/OM_17.07.2026_Hosting%20of%20Note%20on%20CRS%20in%20AIS.pdf
4. Lakshmikumaran & Sridharan — non-disclosure of foreign assets: ownership, valuation and the penalty threshold under the Black Money Act — https://www.lkslaw.com/insights/articles/non-disclosure-of-foreign-assets-in-the-itr-ownership-valuation-threshold-for-penalty-under-the-black-money-act/
5. TaxTMI — the Finance (No. 2) Act, 2024 amendment to section 43 — https://www.taxmanagementindia.com/visitor/tmi_faq_details.asp?ID=1187
6. TaxGuru — Received a foreign assets e-mail for AY 2026-27: what it means — https://taxguru.in/income-tax/received-foreign-assets-email-ay-2026-27-means.html
7. TaxGuru — fake income-tax penalty e-mail with a 72-hour deadline (3 September 2026) — https://taxguru.in/income-tax/fake-income-tax-penalty-email-72-hour-deadline-scam.html