Hi,
I have a query regarding ITR2, I have received RSU stocks other than ESOP and is been maintained in UBS account. I have made 2 entries in section A3 of Schedule FA, one for RSU details vested on 1st Jan 25 and other of all the stocks hold as of 31st Dec 2025. My question is should I separtely fill out Section A2. Details of Foreign Custodial Accounts held ? or should the 2 entries in A3 good enough?
To be fully compliant when filing your ITR, you must report both the UBS account details in Section A2 and the specific RSU stock holdings in Section A3 of Schedule FA. Providing information only in Section A3 is insufficient; you must complete both sections to accurately disclose your foreign assets.
The earlier reply is correct: both sections must be filled.
Section A2 (Foreign Custodial Account) captures the UBS account itself , account number, bank name, country, balance as of December 31, 2025, and peak balance during the calendar year. This is the account container.
Section A3 (Foreign Equity and Debt Interest) captures each RSU holding inside that account , company name, number of shares, ISIN, acquisition cost, and market value as of December 31, 2025.
CBDT requires both sections because the reporting obligation has two layers: the financial account (under FEMA and the Foreign Account Tax Compliance Act exchange mechanism) and the underlying asset. Filling only A3 without A2 leaves the account itself undisclosed, which the system cross-checks.
Consequence of missing Section A2:
An incomplete Schedule FA can trigger a defective-return notice under Section 139(9). More seriously, under the Black Money (Undisclosed Foreign Income and Assets) Act 2015, failure to disclose a foreign financial account , even accidental , carries a minimum penalty of 3 times the undisclosed amount plus possible prosecution. This is worth getting right the first time.
On perquisite valuation: if these RSUs vested on January 1, 2025, the fair market value on that vesting date was treated as salary income (perquisite under Section 17(2)) and should have been taxed and included in your Form 16 for FY 2024-25. For Schedule FA in AY 2026-27, declare shares held on December 31, 2025 at the closing price on that date in the foreign currency, converted to INR at the RBI reference rate.
This ESPP and employee stock tax guide (https://taxgarden.in/blog/espp-employee-stock-purchase-plan-tax-india-ay-2026-27) covers perquisite valuation and Schedule FA disclosure requirements for employer stock plans including RSUs.
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