Hello Everyone,

I need guidance on reporting requirements for an Indian company having a foreign subsidiary.

We have an Indian company, and under this Indian company we have a USA subsidiary company. The USA subsidiary maintains its books in USD, and USD is its primary/default currency.

Our CA has suggested that for the USA subsidiary, we should also report/maintain all transactions in INR because of Indian regulatory requirements.

I want to understand the correct compliance position:

  1. Under the Companies Act, 2013, Schedule III, AOC-1, Ind AS / AS, FEMA or ODI rules, is it mandatory for a foreign subsidiary to maintain or report transaction-level INR details?
  2. Or is it sufficient to maintain the USA subsidiary’s books in USD and translate the trial balance / financial statements into INR for Indian parent company consolidation and statutory reporting?
  3. For consolidation in India, what is the usual practical approach followed by companies?
    • Monthly INR-translated TB
    • Year-end translated financial statements
    • Dual-currency transaction-level reporting
  4. If transaction-level INR reporting is required, which specific section, rule, form, or accounting standard requires it?

My current understanding is that Section 129(3), Schedule III, AOC-1, and Ind AS 21 / AS 11 mainly require consolidation and INR presentation/translation. However, I am not able to identify any direct requirement to maintain every USA transaction in INR also.

Requesting members to share practical guidance and relevant legal/accounting references.