Fidelity Closed Lots CSV for Schedule FA

7 min read · Updated July 2026 · Applies to AY 2025-26 and AY 2026-27

Fidelity's export screen labels these tabs Current shares and Previously held shares. ITRFA.in refers to them as open lots and closed lots — same files, same data.

Why Open Lots (Current Shares) alone is not enough

When you sell shares, those lots move out of Fidelity's Current shares tab — open lots — and into Previously held shares — closed lots. If you rely only on the Current Shares CSV, every lot you sold during the year is missing from your disclosure — even though you held those shares during the calendar year and must report them.

This is exactly why a complete Schedule FA from Fidelity often needs three exports: Current Shares (open lots), Previously Held Shares (closed lots), and Transaction History. See the full Fidelity → Schedule FA walkthrough for the export steps.

When do you need the Closed Lots CSV?

Sell-to-cover counts as a sale

On many vests, Fidelity automatically sells a portion of the shares to cover tax withholding. Even though you did not place the order, those shares were briefly held and then sold — so they are reported in Table A3 with a zero closing value and their proceeds. They appear under Fidelity's Previously held shares (closed lots), not Current shares (open lots).

"But those shares were never allotted to me" — the official position

A common objection — sometimes from CAs — is that sell-to-cover shares should be excluded because they were "never allotted" to the employee. The Income Tax Department's own guidance says otherwise. The department's Step-by-Step Guide to Fill FSI, TR, and FA Schedule in ITR, published on incometax.gov.in as part of the CBDT's foreign-assets compliance campaign, states:

"Taxpayers must furnish details of foreign assets or accounts of the following nature, held at any time during the relevant calendar year ending on December 31st… Table A3 — Foreign Equity and Debt Interest: Investments in foreign equities and debt instruments, including initial value, peak value, closing value, gross interest paid, total gross amounts paid or credited, and proceeds from sale or redemption."

The test is "held at any time during the calendar year" — not held on December 31 — and Table A3's sale-proceeds column exists precisely for shares acquired and sold within the same year. There is no minimum holding period.

The shares were also, in fact, allotted to you. In sell-to-cover the full vested lot is deposited to your brokerage account and the broker sells a portion on your behalf — which is why the sold lots appear in your Previously Held Shares CSV (closed lots) with a vest-date acquisition, why your US Form 1099-B reports the sale in your name, and why your Form 16/12BA perquisite under Section 17(2)(vi) of the Income-tax Act (which taxes shares "allotted or transferred" by an employer) was computed on the entire vest, sold shares included. The "never allotted" argument only fits net share settlement, a different mechanism in which the employer withholds shares before issuance and they never reach your account — those lots don't appear in your broker statements at all. If your Closed Lots CSV shows them, they were yours.

How a sold lot maps to Table A3

The lot still appears even though you no longer hold it — it was a foreign asset you held during the calendar year. For the correct ESPP initial value (FMV vs purchase price), see the ESPP guide; for vest-date rules see the RSU guide.

Common errors with sold lots

• Omitting sold lots entirely. Incomplete disclosure carries Black Money Act risk — your vesting history is visible to the department via employer TDS and FATCA/CRS.
• Using March 31 instead of Dec 31. Schedule FA follows the calendar year; a lot sold in November has a Dec 31 closing value of 0.
• Leaving proceeds blank. Report gross sale proceeds (before fees/withholding) at the SBI TTBR on the sale date.

Shares sold in January of the next year

If you sold shares in January 2026, they were still held on 31 Dec 2025 — so for CY 2025 (AY 2026-27) they are reported with their Dec 31 closing value, and they appear again the following year with a zero closing value plus proceeds. The same lot can legitimately appear in two consecutive years' Schedule FA with different closing values.