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Did Your CA File Schedule FA Correctly? A Self-Audit Checklist

6 min read · Published July 2026 · Applies to AY 2025-26 and AY 2026-27

Many people who file through a CA assume RSUs/ESPP are "handled" because tax was deducted and a capital gain was reported on a sale. Schedule FA is a separate, easy-to-miss section — this checklist tells you exactly what to look for in your own filed return.

If you hold US employer stock and file through a chartered accountant, you are still the one who signs the return. It is worth spending ten minutes checking what was actually filed, especially for the years before Schedule FA became a routine part of RSU/ESPP filings for many practices.

Step 1 — get your actual filed return, not a summary

Log in to the income tax e-filing portale-File → Income Tax Returns → View Filed Returns, and download the ITR in JSON or PDF for each year you want to check. A computation sheet or Form 16 from your CA is not the same thing — you need the actual filed schedules.

The 6-point checklist

#CheckWhat "wrong" looks like
1 Schedule FA section exists at all, with entries in Table A2 (account) and Table A3 (shares) ITR-1 was filed (it has no Schedule FA), or ITR-2/ITR-3 was filed but the Schedule FA section is blank
2 Every foreign broker account is listed — not only the one that had a sale that year You held RSUs at two employers over the years (job change) but only the most recent broker appears
3 Peak value and Dec 31 closing value are both filled, and the closing date is December 31, not March 31 Values look identical to your salary-schedule figures, or the closing date matches the Indian financial year end instead of the calendar year
4 Unvested RSUs are disclosed as beneficial interest, if you had any that year Only vested/sold shares appear; unvested grants are absent entirely
5 Form 67 was filed on or before the return, if a foreign tax credit was claimed Schedule TR shows a credit claimed, but no Form 67 was filed, or it was filed after the return — see Form 67 & FTC
6 Sold/sell-to-cover lots still appear in Table A3 with closing value 0 plus proceeds — they are not simply dropped A lot sold mid-year is missing entirely from Table A3, as if it never existed

"But my RSU income is in Form 16 and I reported the sale in Schedule CG"

That is a common and reasonable-sounding assumption — and it is the single most frequent gap this checklist catches. Form 16 and Schedule CG report income: the perquisite value at vest, and the gain or loss on a sale. Schedule FA reports the asset itself — the brokerage account and the shares in it — and applies every year you hold the asset, whether or not it produced any income that year. One does not substitute for the other; see why "I already paid tax" doesn't cover the disclosure obligation.

If you find a gap

  • Current/still-open assessment year: file a revised return with the corrected Schedule FA before the revision deadline — see Schedule FA deadlines.
  • Past, closed years: talk to a CA about your options. If the underlying RSU/ESPP income was genuinely taxed each year and only the Schedule FA disclosure was missed, this is exactly the fact pattern the FAST-DS 2026 amnesty scheme is designed for, once it opens. Read what the Black Money Act penalty actually is before assuming the worst — and before assuming nothing is wrong.
  • Going forward: you don't need to switch CAs to fix this — sharing this checklist with your current one, and pulling your own broker export as a cross-check, is usually enough.
This checklist tells you what to look for, not what your specific situation requires. Whether and how to correct a past gap is a decision to make with a chartered accountant, based on your actual filed returns.
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Related guides

Informational only, based on current law (FY 2025-26 / AY 2026-27). This is a self-check tool, not a substitute for professional review — consult a chartered accountant about any gap you find.