Any penalty for not filing schedule FA because her total income was less than threshol

I am asking for a senior citizen who is also US citizen but since May 2018 she resides in India and for tax purpose she is Indian resident since than.

For the year 2018/2019 - her total income was less than threshold of 3 lac and for 2020 we are filing her tax return with Sch FA (foreign assets)

But I just found that even if her total income was less than threshold, just because she had foreign bank account - she was supposed to file tax return in India - but she did not file ...

So question is for the year 2018 and 2019 - she has to pay penalty for not filing return as well as not filing SCH FA?

Tax and penalty for undisclosed assets are high. Here it is

"Undisclosed foreign income or assets are taxed at 30% plus a penalty, which is 300% of the tax payable on the income or value of the undisclosed asset. An additional penalty of Rs 10 lakh may be levied for failure to disclose such foreign assets in the return."

On ITR efiling it ask when was this account opened - can we put a date that starts in January 2020 to avoid any possible penalty ..are they going to check with US bank as to when this account was actually opened?

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