Reporting foreign income, Assets to RBI by Dec 24

We ,an unlisted public limited company, are having WOS in Mauritis, who in turns controls step down subsidiary. There was certain mis-clarification in equity& redeemable preference share and project profile amendment is under process thru  AD. Since there are changes in step down subsidiary,  pending amendment, AD advises us not to submit APR, FLA.

However beyond December, RBI will impose penalty .

How to address this dilemma 

Kindly guide1