CORAA

Black Money Act — Schedule FA Foreign Asset Disclosure Checklist

A category-by-category check of whether this individual/entity holds foreign assets or has foreign income requiring Schedule FA disclosure in the return, and whether the Black Money Act's own reporting obligations apply.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Statutory basis
Black Money Act 2015 + Schedule FA of the ITR
Who discloses
Resident and ordinarily resident taxpayers (individuals: ROR status)
Threshold
None for the disclosure obligation itself — verify computation/penalty thresholds separately
Note
This is a disclosure-compliance checklist, not a legal opinion or finding of any violation
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What’s inside

An excerpt from the template.

BLACK MONEY ACT / SCHEDULE FA — FOREIGN ASSET DISCLOSURE CHECKLIST

Name: ___ · PAN: ___ · As at / for the year: ___

Purpose: this checklist tests, category by category, whether a resident (ordinarily resident, for individuals) taxpayer holds any foreign asset or has any foreign income requiring disclosure in Schedule FA of the Income-tax Return, and separately whether the reporting and disclosure requirements under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 apply. Schedule FA disclosure is required of a resident and ordinarily resident taxpayer regardless of the value of the foreign asset — there is no minimum threshold for the disclosure obligation itself, only for certain computation and penalty provisions.

Where any category above is answered "Yes" but "Disclosed in Schedule FA?" is "No" or the return has already been filed without the disclosure, consider whether the taxpayer should file a revised return (if still within the permitted time) — the Black Money Act imposes its own, separate and severe consequences for non-disclosure, over and above ordinary income-tax provisions.

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About this template

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This template follows the format published by the Institute of Chartered Accountants of India (ICAI) in the AASB Audit Working Paper Templates (June 2023), the authoritative reference for Indian statutory-audit documentation. Fill in your firm’s letterhead and the engagement details on the form above, click Download Word file, and you’ll get a fully formatted .docx ready to use.

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Common questions

FAQs.

Who is required to file Schedule FA?
A resident and ordinarily resident individual (or the equivalent residential-status test for other categories of assessee) who holds any foreign asset or has any foreign income at any time during the relevant calendar year (Schedule FA uses a calendar-year reporting period, not the financial year) must complete Schedule FA in the return, regardless of the asset's value — non-residents and residents-but-not-ordinarily-resident are generally outside this specific disclosure requirement.
What are the consequences of not disclosing a foreign asset in Schedule FA?
The Black Money Act 2015 provides for a substantial penalty (a fixed sum per year of non-disclosure, verify the current amount) independent of any income-tax demand, and in more serious cases can carry prosecution consequences — separate from and in addition to whatever tax is separately due on any related undisclosed foreign income. This is a materially harsher consequence regime than an ordinary income-tax disclosure lapse.
Does holding a small foreign bank balance still require disclosure?
Yes — unlike many other reporting thresholds in Indian tax law, Schedule FA disclosure of foreign bank accounts and other foreign assets generally has no minimum value threshold for the disclosure obligation itself; even a dormant or low-balance foreign account held by a resident and ordinarily resident taxpayer should be disclosed. Some computation/valuation thresholds exist for other purposes under the Act — verify these separately from the disclosure obligation.
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