My close relative has received SMS for "Foreign Assets of Small Taxpayers - Disclosure Scheme, 2026 (FAST - DS)" couple of days back.

He was at onsite in below locations:
Country 1: Dec 2014 - Oct 2016
Country 2: Nov 2017 - Oct 2018

During these periods, he had received salary in his foreign bank accounts which he had transferred to his Indian account over a period of time.

As per AI, his resident status for those years is as below:
2014-15 : resident
2015-16 : non-resident
2016-17 : resident
2017-18 : resident
2018-19 : resident

He never declared foreign assets in Schedule FA. Also, except for 1 year, he never declared his foreign income in ITR. Even for that 1 year, he think he had declared incorrectly.

His 2 foreign accounts for country 1 and 2 respectively might be still active but with almost 0 balance since 2019.
He checked in AIS portal and can see his Country 2's bank account listed for CY 2022. Nothing for CY 2023 and 2024 yet.

He did his own research so far and feels like he is in a really bad situation.
1. If he go for Fast DS then, he need to pay heavy penalty of 60% of total undisclosed foreign income. Suppose total income for all those years is 50 lakhs(just example not calculated yet) then he will have to cough up 30 lakh in penalty.
2. If he doesn't go for Fast DS then he might risk even heavier penalty under BMA and possible litigation in ITAT or courts whenever they send SCN.

He is really frustrated with all this because it was never his intention to not disclose foreign salary. In fact, he could have claimed FTC on it.
People didn't had as much awareness or resources way back than we have now like AI, etc.

All of it is white money, earned through proper work. It feels so sad that Govt. wants to penalize people so hard by takng 60% of it.
This is not at all logical. How can they penalize genuine hard working people like this and call it Amnesty? They should allow people to disclose it now without any fees(or minimal charges).

After reading several online posts, it feels like there are diff. perspectives as below:
1. Govt is actually allowing us to disclose with less penalty so it's a better option than facing heavier penalty later.

2. Several ITAT verdicts similar to his(and other scenarios as well) have gone in favor of individuals due to DTAA. It feels like Govt. might be trying to spread fear to collect more money quickly. It might be better to fight this in tribunal later if required but it will involve lawyer's cost.
Some examples:
Kapil Gupta - India - Australia DTAA, Articale 5, Delhi
Manikandan Rajapacklaeswaran v. ACIT - Channai ITAT, 24 oct 2025

3. Wait and see if Govt. further clarifies on the doubts regarding Fast DS. Lets not hurry in availing this scheme.


Just looking for inputs and guidance from you all as what he should be doing now and what penalty he might have to face.


Thanks in advance!