For many NRIs and returning residents, “Black Money” is a term associated with high-profile scams. However, under the strict Black Money Act (BMA) 2015, even a forgotten $50 savings account from a college stint in the US or an old ESOP from a past job can technically fall under this category if not reported in your Indian Tax Return (Schedule FA).
The Union Budget 2026 has introduced a rare, time-bound “exit door” called the FAST-DS 2026. If you have overseas assets, this might be the most important six-month window of your financial life.
Before we look at the solution, let’s look at the problem. If a resident Indian fails to disclose a foreign asset:
The Penalty: A flat ₹10 Lakh per year of non-disclosure.
Prosecution: Up to 7 years of rigorous imprisonment.
No Expiry: Unlike regular income tax, there is no “time limit” for the department to reopen cases under the Black Money Act.
The FAST-DS 2026 wisely differentiates between someone trying to hide income and someone who simply made a reporting mistake.
Who it’s for: People who bought foreign assets with money that was never taxed in India or earned foreign income (like dividends/rent) and never declared it.
Eligibility: Aggregate value of assets/income up to ₹1 Crore.
The Cost: 60% total payout (30% Tax + 30% Penalty) on the Fair Market Value (FMV) as of March 31, 2026.
The Benefit: Complete immunity from prosecution and no further penalties.
Who it’s for: The “Techie Special.” You earned RSUs/ESOPs while working abroad or used tax-paid salary to buy shares, but you forgot to fill Schedule FA in your ITR.
Eligibility: Aggregate asset value up to ₹5 Crores.
The Cost: A flat ₹1,00,000 fee.
The Benefit: This is a massive relief. Instead of potentially losing 120% of your asset value in penalties, you settle the entire past default for just ₹1 Lakh.
The 2026 Act provides a separate permanent relief for very small holdings. If your aggregate foreign movable assets (excluding real estate) do not exceed ₹20 Lakh, the department generally will not initiate prosecution for inadvertent non-disclosure.
Warning: This does not mean you shouldn’t disclose them. Disclosure remains mandatory for all residents.
If you answer “Yes” to any of these, you need to evaluate the FAST-DS window:
[ ] Do you have a dormant bank account in the UK/US/UAE from a previous stint?
[ ] Did you receive ESOPs or RSUs from a foreign parent company (e.g., Google, Amazon, Microsoft)?
[ ] Do you hold a “Cash Value” life insurance policy or annuity taken abroad?
[ ] Are you a “Resident” in India now, but still hold a brokerage account (Vanguard, Charles Schwab) overseas?
The Income Tax Department now receives automatic data from over 100 countries through the Automatic Exchange of Information (AEOI). They likely already know about your account; the FAST-DS 2026 is your chance to tell them before they send you a notice.
At Husain A Shujai and Associates, we specialize in NRI cross-border taxation. We can help you calculate your FMV, categorize your assets correctly, and file your FAST-DS declaration to ensure your “exit” is clean and permanent.
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