By IndiaHub 
Taxpayers who have been sent such mails now need to report this income in revised ITR till December 31, 2025.
But which foreign assets do they report about? Who needs to report these assets? And what can be consequences if someone fails to report these assets in revised ITR? Let’s see what chartered accountants say about it-
What does Income Tax Department’s email to taxpayers say about disclosure of foreign assets?
The Income Tax Department’s mail reads: “Data has been shared by foreign jurisdiction(s) showing that you held or earned foreign assets or income (e.g., bank accounts, interest, dividends, investments) during Calendar Year 2024. However, Schedule Foreign Assets was not included in your ITR for Assessment Year 2025-26. Please revise your ITR by 31st December to report these foreign assets or income. Please include any foreign assets or income held or earned during the year, to ensure that your return is complete and accurate.”
What type of foreign assets should be reported in ITR?
CA Jigar Suba (founder of JC Suba & Associates, Chartered Accountant) says the foreign assets (in ITR) include-
⮚ Any property outside India (Land, flat, commercial complex or any other property whatsoever)
⮚ Bank account in foreign country even if it’s a dormant account
⮚ Joint owner/ co-owner in foreign assets/ accounts
⮚ Insurance policies outside India
⮚ Signatory authority in foreign account
⮚ Shares & mutual funds in foreign country
⮚ RSU’s & ESOP
⮚ Pension or retirement benefit account
⮚ Crypto or any other digital asset
⮚ Trust created outside India
Any other capital asset (excluding stock and business asset)
“The Black Money Act, 2015 (BMA) does not create a separate disclosure requirement. However, if a foreign asset is not disclosed in the ITR and the assessee fails to satisfactorily explain the source of investment, such asset may be treated as an undisclosed foreign asset, attracting penal consequences as discussed in below paras,” Suba told ET Wealth Online.
Who are required to file revised ITR?
Taxpayers should revise their ITR if they have any foreign assets or income that were missed to be reported in ITR earlier, says Abhishek Soni, CEO & Co-founder, Tax2win.
“This mainly includes salaried individuals who received ESOPs, RSUs, or shares from foreign employers, bonus shares, or those who hold foreign bank accounts. Even if there is no income from these assets, disclosure is mandatory,” says Soni.
Suba says only resident and ordinarily resident individuals for FY 2024-25 should revise their ITR if:
- Schedule FA was not filled, or
- Incorrect or incomplete details of foreign assets were reported
Note that Schedule FA is separate from Schedule AL and must be filled independently, Suba emphasises.
Who are not required to file revised ITR?
If you don’t have any income or have already made the foreign asset/income disclosure in ITR in the past years and in the present year there is nothing to disclose, then you don’t need to file any revised or belated ITR. However, if you can’t explain the source of the funds i.e. unexplained investments then you need to file a revised or belated ITR and disclose it.
Non-residents (NR) and RNORs are not required to disclose foreign assets.
Should you report a foreign asset if you haven’t earned any income from it?
This (foreign asset/income) has to be reported irrespective of the fact that, whether any income is earned or not on such asset, whether any tax is paid or not on such asset outside India, the date of purchase does not fall within the current year, value of the asset, explains Suba.
Which form do you need to use for filing revised ITR?
CA Abhas Halakhandi says that many taxpayers also need to ensure they are using the correct return form (typically ITR-2/ITR-3 for foreign assets/income reporting, not ITR-1/ITR-4) while revising.
Can Income Tax Department punish you if you fail to report foreign income in revised ITR?
Non-compliance can lead to heavy penalties under the Black Money Act, says Soni. “Penalties can go up to Rs 10 lakh for non-disclosure of foreign assets, along with possible prosecution in serious cases. Revising the return within the allowed time helps taxpayers avoid these consequences,” Soni explains.
Asset may be treated as undisclosed foreign asset under the BMA and 30% of asset value could be recovered as tax, says Suba, adding that failing to report foreign income in revised ITR may attract scrutiny/re-assessment under the provisions of the Income Tax Act.