Schedule FA (Foreign Assets) is a crucial section in the Indian income tax return that mandates residents to report their foreign income and assets. Introduced as part of the broader framework to curb black money and undisclosed foreign income, Schedule FA plays a vital role in enforcing tax compliance and transparency.
The Indian Income Tax Department requires individuals who qualify as residents under the Income Tax Act, 1961, to disclose specific information about their foreign holdings. The reporting includes bank accounts, financial interests, trusts, and any immovable property located outside India.
This form aligns with global standards on financial transparency and complies with international commitments like the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS).
The Need for Schedule FA
The primary objective of Schedule FA is to ensure residents do not evade tax by holding unreported assets abroad. Globalization has increased cross-border financial activity, making it easier for individuals to hide assets.
To address this, India strengthened its legal framework through the introduction of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015, commonly referred to as the Black Money Act. This legislation provides the legal backing for punitive measures against taxpayers who fail to report foreign assets accurately.
Who Must File Schedule FA
Schedule FA is mandatory for individuals qualifying as “resident and ordinarily resident” (ROR) in India. The classification is based on the number of days spent in India during a financial year and the preceding years. Non-residents (NRIs) and resident but not ordinarily resident (RNOR) individuals are not required to file Schedule FA.
Filing is required even if the foreign assets do not generate any income or if income earned has already been taxed abroad. The scope of disclosure includes not only directly owned assets but also assets held as a beneficial owner or beneficiary.
Types of Foreign Assets Reportable
The Income Tax Rules require disclosure of the following categories in Schedule FA:
Foreign Depository Accounts
Any bank or financial institution account held outside India, regardless of the balance or account activity, must be reported. This includes savings, current, or time deposit accounts.
Foreign Custodial Accounts
Custodial accounts that hold financial instruments or securities abroad must also be disclosed. This applies even if the account does not currently generate income.
Foreign Equity and Debt Interests
This covers any shares or debt interests held in foreign companies or entities. It includes both listed and unlisted instruments.
Foreign Cash Value Insurance Contracts or Annuity Contracts
Any life insurance policies or annuity contracts where the taxpayer is the policyholder must be disclosed. This includes unit-linked insurance plans (ULIPs) offered by foreign insurers.
Financial Interest in Any Entity
This refers to the ownership of voting rights or capital interest in foreign companies, partnerships, or trusts.
Immovable Property Outside India
All foreign properties, whether inherited, purchased, or gifted, must be reported. The location, size, and ownership type must be detailed.
Trusts, Trust Beneficiaries, and Beneficial Ownership
If the taxpayer is a trustee, settlor, or beneficiary of any trust located outside India, those interests must be disclosed.
Other Capital Assets Held Abroad
This category includes artwork, jewelry, or any other capital asset held outside India.
Reporting Structure in Schedule FA
Schedule FA has a detailed format and is divided into the following parts:
A1: Details of Foreign Depository Accounts
It requires name and address of the institution, country code, account number, account opening date, peak balance during the year, and the amount of interest accrued or credited.
A2: Details of Foreign Custodial Accounts
Similar to A1, but specifically for custodial holdings of stocks, mutual funds, and bonds.
A3: Details of Foreign Equity and Debt Interests
This section demands the name and address of the entity, nature of interest, date of acquisition, and income earned.
A4: Details of Insurance and Annuity Contracts
Information like name of the insurance company, policy number, contract start date, and surrender value is included.
A5: Details of Financial Interest in Entities
Disclosures must include ownership percentage, capital contribution, nature of interest, and income earned.
A6: Details of Immovable Property
Location, address, ownership share, acquisition date, and cost of acquisition are to be reported. If the property is on leasehold or freehold, that must also be indicated.
A7: Details of Trusts
This requires the name of the trust, the role of the taxpayer (settlor, trustee, or beneficiary), country code, and income details.
A8: Details of Other Foreign Assets
Assets not falling under earlier categories but owned outside India should be reported here, including cryptocurrency, if held overseas.
A9: Details of Any Other Income Derived from Foreign Assets
This captures income not directly tied to a specific asset, such as royalties or business income from abroad.
Legal Framework and Compliance
Income Tax Act, 1961
Section 139(1) mandates the furnishing of a return if a person qualifies as a resident and has assets located outside India. Non-compliance can result in substantial penalties.
Black Money Act, 2015
The Act provides for separate taxation of undisclosed foreign income and assets, with a flat rate of 30 percent tax and penalties up to 90 percent of the value of the asset.
It empowers tax authorities to initiate prosecution proceedings with imprisonment of up to 10 years for willful default.
FEMA Regulations
In addition to tax laws, the Foreign Exchange Management Act (FEMA) also governs acquisition and holding of foreign assets. Any violation of FEMA provisions can lead to civil penalties.
Importance of Due Diligence
Taxpayers must maintain robust documentation regarding foreign asset acquisition, income generated, and taxes paid abroad. Misreporting, even if unintentional, may attract penalties under the Black Money Act.
Consulting with legal and tax advisors is strongly recommended, especially for individuals with complex global portfolios.
Exchange Rates and Valuation
Valuation of foreign assets and income must be done in Indian rupees. The exchange rate notified by the Reserve Bank of India as on the last day of the financial year is to be used.
Fair market value is generally required for immovable property and unlisted financial instruments. Incorrect valuation or use of the wrong exchange rate can be treated as misreporting.
Consequences of Non-Disclosure
Failure to disclose foreign assets in Schedule FA may attract:
- Penalty of INR 10 lakh per defaulted asset under the Income Tax Act
- Separate penalties under the Black Money Act
- Initiation of prosecution proceedings
- Disqualification from compounding penalties in future
Moreover, data-sharing agreements with other countries under FATCA and CRS frameworks allow Indian authorities to trace assets and initiate proceedings.
Exceptions and Exemptions
Some exemptions exist under Schedule FA reporting. Individuals who are not residents for the financial year or those who hold assets in the capacity of nominees without any beneficial interest may not be required to report.
Small balances in foreign bank accounts, particularly for students or travelers abroad, may be exempt from penalties if there is no income generation and assets are declared promptly upon return to India.
Timeline for Filing Schedule FA
Schedule FA must be filed along with the income tax return (ITR), generally due by July 31st for individual taxpayers. If the taxpayer qualifies for audit under section 44AB, the due date extends to October 31st.
Delayed filing or revision beyond the allowed timeline may not shield the taxpayer from penalties if foreign assets were omitted.
Comparison with Previous Years
The structure of Schedule FA has evolved to include additional fields for country code, account opening dates, and peak balances. The government has also introduced electronic verification and pre-filing of data received from foreign institutions.
Earlier, voluntary disclosure under the Income Declaration Scheme (IDS) was allowed, but now, undisclosed foreign assets attract severe penalties without recourse to amnesty schemes.
Global Cooperation and Information Exchange
India has signed intergovernmental agreements (IGAs) with the U.S. under FATCA and with several other nations under CRS. These agreements mandate financial institutions to report accounts held by Indian residents to Indian tax authorities.
This global cooperation has strengthened enforcement capabilities and led to an increase in cases related to non-disclosure under Schedule FA.
Common Challenges in Reporting
Some of the issues faced by taxpayers include:
- Identifying reportable assets when foreign holdings are complex
- Estimating fair market value
- Reconciling foreign tax credits with Indian tax liability
- Reporting shared ownership or joint accounts
Taxpayers must pay attention to the nuances of each asset type, particularly in cases of indirect ownership or inherited assets.
Case Studies and Precedents
Indian courts have upheld the stringent provisions of the Black Money Act in cases where taxpayers failed to report foreign bank accounts despite holding them for decades. Voluntary compliance before detection has been seen as a mitigating factor in some cases, reducing penalties.
However, courts have also ruled that ignorance of the law is not a valid defense for non-disclosure.
Introduction to Reporting Obligations
The Foreign Asset (Schedule FA) reporting requirement has grown in importance as regulatory frameworks around the world increasingly emphasize financial transparency. Non-disclosure of foreign assets not only leads to financial penalties but may also involve prosecution under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015. Delves deeper into specific types of assets to be reported, their disclosure formats, and the risks of inaccurate reporting.
Categories of Foreign Assets Covered
Schedule FA requires taxpayers to disclose a wide array of foreign holdings. Understanding these categories is crucial to ensure full compliance.
Foreign Depository Accounts
Depository accounts include savings and checking accounts held in overseas banks. Taxpayers must report details such as the country where the account is held, the name of the financial institution, account number, and peak balance during the year.
Custodial Accounts
Custodial accounts refer to those in which the financial institution holds securities or other assets on behalf of the taxpayer. This may include brokerage accounts and must be disclosed with all relevant details, including the highest value during the year and whether the account was active.
Equity and Debt Interests
Individuals must report ownership in foreign entities, such as shares in companies or debt instruments. This also includes interests in limited liability partnerships or other legal entities. Essential information includes the name of the entity, country of incorporation, nature of interest, and the percentage of ownership.
Immovable Property
Foreign real estate assets such as land, residential or commercial properties owned outside India need to be declared. Required details include the address, country of location, nature of ownership (direct or through an entity), date of acquisition, and cost of acquisition.
Accounts in Foreign Trusts
If an individual is a trustee, beneficiary, or settler of a foreign trust, those interests must be disclosed. This includes describing the trust’s purpose, nature of interest, and identification of the trust structure.
Other Capital Assets
Any other foreign capital asset not covered above, such as artwork, patents, or precious metals held overseas, also falls under this disclosure requirement.
Valuation Principles for Foreign Assets
Accurate valuation is critical for correct reporting. Valuation must be based on fair market value or cost of acquisition, depending on the asset type. For instance, publicly traded shares should reflect the market price as on the valuation date, whereas unlisted equity or real estate requires an appropriate valuation report, often from a certified professional.
Valuation should be converted into Indian currency using the reference rate notified by the Reserve Bank of India on the last day of the relevant financial year.
Income Derived from Foreign Assets
Any income arising from foreign assets, such as dividends, interest, rent, or capital gains, must also be disclosed. Even if such income is not taxable under the Indian Income Tax Act due to treaty benefits or exemption provisions, disclosure in Schedule FA remains mandatory.
Treatment of Jointly Held Foreign Assets
Joint ownership does not exempt individuals from disclosure. Where the taxpayer is a co-owner, their share in the asset must be disclosed. This includes specifying the ownership ratio and the total value of the asset.
In cases of multiple co-owners, individuals must ensure their declared share matches their actual legal or beneficial ownership.
Applicability to Non-Residents and Resident but Not Ordinarily Residents (RNOR)
Schedule FA requirements primarily apply to individuals who qualify as residents under Indian tax law. However, Resident but Not Ordinarily Resident (RNOR) individuals are required to disclose foreign income or assets that are derived from a business controlled or profession set up in India.
Non-residents are generally outside the scope of Schedule FA unless they are otherwise considered residents due to stay periods or deemed residency rules.
Disclosure of Foreign Bank Accounts Opened for Employment or Education
Accounts opened abroad for the purpose of employment or study abroad must also be disclosed. Individuals often misunderstand this requirement, assuming that foreign salary accounts or student accounts are exempt. As long as the individual qualifies as a resident for the financial year, such accounts fall under Schedule FA disclosure.
Reporting of Foreign Pension Funds
Foreign pension accounts, such as 401(k) or superannuation funds, are also required to be disclosed. The reporting should include account balances, contribution details, and any income accrued or withdrawn during the year.
Omission of foreign pension accounts is a common oversight, which can lead to unwanted scrutiny.
Treatment of Gifted or Inherited Foreign Assets
Foreign assets received as gifts or inheritance must be reported, even if no income is generated from them.
Disclosure must include the date of receipt, donor or estate details, and the nature and value of the asset. If the asset is jointly inherited, the reporting individual must disclose their proportionate share.
Role of Financial Institutions in Foreign Jurisdictions
Indian authorities may use information-sharing agreements with foreign financial institutions to verify disclosures. The Common Reporting Standard (CRS) and Foreign Account Tax Compliance Act (FATCA) agreements enable this exchange.
This increases the risk for individuals attempting to underreport or omit foreign holdings, as discrepancies can be directly detected.
Due Diligence Before Filing Schedule FA
Taxpayers should perform a thorough review of their global holdings before filing. Due diligence should cover:
- Reviewing historical bank statements and investment reports
- Engaging professionals to value complex assets
- Confirming classification of ownership (beneficial vs legal)
- Identifying indirect ownership via trusts or entities
Carelessness or negligence in this process can lead to serious consequences under the Black Money Act.
Impact of Double Taxation Avoidance Agreements (DTAAs)
While DTAAs may provide relief from double taxation, they do not provide immunity from disclosure. The taxpayer must still report foreign assets in Schedule FA, even if tax liability is offset by a DTAA benefit.
DTAA claims are generally made in the main return form, but asset disclosure remains compulsory in Schedule FA.
Difference Between Schedule FA and Schedule FSI
Schedule FA deals with foreign assets, while Schedule FSI (Foreign Source Income) captures income earned outside India and taxes paid abroad. Although both schedules address international elements, they serve different compliance purposes.
Omitting either or both can lead to misreporting, especially in the case of Indian residents with international financial interests.
Common Errors Made by Taxpayers
- Failure to include jointly held accounts
- Non-disclosure of inactive or dormant accounts
- Misclassification of accounts under incorrect categories
- Incorrect valuation of assets
- Not reporting foreign pensions or retirement funds
Such mistakes, even if unintentional, can invite significant penalties under the Black Money Act.
Amendments and Corrections
If a taxpayer identifies errors after filing the return, they must file a revised return within the allowed window. However, if the omission is considered willful, the opportunity to revise may not protect the individual from penalty or prosecution.
It is advisable to consult with professionals when making corrections to ensure full compliance with both procedural and substantive requirements.
Monitoring by Indian Authorities
The Indian tax department has enhanced its scrutiny through automated tools and international collaboration.
Flags are raised for any mismatch between international data and Indian filings. Special attention is given to high-net-worth individuals and frequent travelers. Taxpayers must not assume anonymity or low detection probability for undeclared foreign income or assets.
Role of the Black Money Act in Deterrence
The Black Money Act was enacted to act as a powerful deterrent against tax evasion through foreign assets. Its scope goes beyond taxation into the realm of criminal enforcement, including prosecution and confiscation.
This legislative environment underscores the need for careful and truthful reporting under Schedule FA.
Reporting Deadlines and Consequences of Late Filing
The deadline for filing returns, including Schedule FA, typically aligns with the due date for the income tax return (July 31 or extended deadlines as notified). Delays in filing or omission in Schedule FA lead to severe consequences, including:
- Penalty of INR 10 lakh for each default
- Additional penalties for continuous non-compliance
- Risk of prosecution for willful suppression
Timely filing supported by comprehensive documentation is crucial to mitigate such risks.
Interplay with Foreign Exchange Management Act (FEMA)
Non-disclosure of foreign assets may also violate FEMA provisions. If the foreign asset was acquired in violation of FEMA, additional penalties or compounding fees may apply.
FEMA penalties are distinct from income tax and Black Money Act penalties, creating a multi-pronged legal risk. Therefore, taxpayers must ensure that their foreign holdings comply with both tax laws and FEMA.
Importance of Professional Guidance
Given the complexity of Schedule FA and the risks under the Black Money Act, professional assistance from qualified tax advisors and legal experts is often necessary. These experts can help with:
- Evaluating residency status
- Classification of ownership
- Valuation of assets
- Preparing accurate disclosures
- Ensuring legal compliance across jurisdictions
Attempting to navigate these obligations without expert input can be risky, especially for individuals with complex global holdings.
Best Practices
- Conduct a full audit of foreign assets before return filing
- Maintain detailed documentation for each asset
- Convert values using prescribed currency rates
- File within deadlines and avoid revision due to negligence
- Seek professional help for complex or high-value cases
These practices not only ensure compliance but also offer protection from unintentional breaches that may lead to steep consequences.
Enforcement of Schedule FA by Indian Tax Authorities
Enforcement of Schedule FA has become increasingly stringent over the years as Indian authorities prioritize curbing black money and foreign asset evasion. The Income Tax Department uses intelligence tools, global cooperation, and technological platforms to scrutinize foreign disclosures under this schedule.
Notices are often issued under sections 142(1), 148, or 153A of the Income Tax Act when authorities suspect foreign assets have been underreported. Taxpayers may also receive follow-up queries regarding the source of funds, compliance history, and cross-border tax positions. Failure to adequately respond or disclose can prompt deeper audits or prosecution under relevant provisions.
Technology and Data Analytics in FA Scrutiny
The Central Board of Direct Taxes (CBDT) leverages data analytics and risk-based profiling to assess high-risk cases. The integration of information from the Annual Information Return (AIR), Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard (CRS), and Suspicious Transaction Reports (STRs) enhances enforcement under Schedule FA.
Authorities now maintain a centralized repository of foreign transaction data sourced from global databases. Automated risk flags are triggered when inconsistencies are identified between ITR disclosures and foreign financial footprints.
Case Studies of Non-Compliance
Several high-profile enforcement cases illustrate the consequences of incorrect or omitted foreign asset disclosures:
- A taxpayer failed to report a joint foreign bank account inherited from a deceased relative. Despite it not generating income, the omission triggered a show-cause notice and penalty proceedings.
- In another instance, an Indian resident claimed ignorance of a trust formed abroad by a relative in their name. After the trust was discovered through CRS data, the individual faced prosecution under the Black Money Act for willful nondisclosure.
- A professional residing in India disclosed ownership in a Delaware LLC but omitted related foreign bank accounts. The partial disclosure invited reassessment under section 148, leading to tax on deemed income and a penalty.
These examples underscore that even passive holdings, dormant accounts, or inherited assets are subject to disclosure under Schedule FA.
Common Errors While Filing Schedule FA
Despite increasing awareness, several common errors persist during Schedule FA compliance:
- Reporting assets using approximate values instead of actual balances as per accounting periods.
- Using INR instead of the functional foreign currency while reporting balances.
- Misclassifying financial interests as beneficial ownership and vice versa.
- Failing to report foreign pension accounts or employer-issued stock options held abroad.
- Ignoring disclosure of jointly held foreign property if the individual has any partial ownership.
Each of these lapses can lead to legal consequences and financial penalties.
Disclosure Requirements for Specific Asset Classes
Foreign Depository Accounts
Includes bank accounts, fixed deposits, and certificates of deposit. The peak balance must be reported along with the name of the institution and country.
Foreign Custodial Accounts
Securities accounts with brokers and financial institutions fall under this category. Investments held, nature of instruments, and the highest value must be disclosed.
Foreign Equity and Debt Interests
Includes ownership in companies, partnerships, and interest-bearing instruments. Both direct ownership and beneficial interest must be reported.
Foreign Trusts and Foundations
Disclosures include the settlor’s name, trustee and beneficiary details, date of creation, jurisdiction, and the value of assets held by the trust.
Foreign Real Estate and Immovable Property
Ownership or partial ownership of homes, land, or buildings outside India must be disclosed. Details of acquisition cost, current estimated value, and address are essential.
Foreign Retirement and Pension Accounts
Many taxpayers erroneously believe foreign pensions are exempt from disclosure. However, accounts under foreign retirement plans (e.g., 401(k), IRA, etc.) must be disclosed if held during the reporting period.
Foreign Derivatives and Crypto Assets
If a resident holds foreign derivatives or cryptocurrencies on global exchanges, these must be reported under the appropriate asset class. While legislation around digital assets is evolving, Schedule FA expects full transparency.
Link Between Schedule FA and International Agreements
India’s increasing alignment with international frameworks enhances its ability to enforce Schedule FA.
Common Reporting Standard (CRS)
India is part of the OECD’s CRS initiative, which enables automatic exchange of financial account information. More than 100 countries report financial data to India regarding accounts held by Indian residents.
Double Taxation Avoidance Agreements (DTAAs)
Under DTAAs, India receives transactional data and tax-related information on Indian residents from treaty partners. This data is cross-verified with ITR filings to flag Schedule FA violations.
Mutual Legal Assistance Treaties (MLATs)
India uses MLATs to request detailed financial records, including corporate shareholding structures, offshore trust deeds, and property acquisition details from foreign jurisdictions.
Role of Financial Institutions and Intermediaries
Banks, asset managers, tax advisors, and chartered accountants are increasingly held accountable for ensuring clients file Schedule FA correctly. Failure to guide clients or facilitate nondisclosure can trigger regulatory action against intermediaries.
Professionals involved in structuring foreign trusts, setting up shell companies, or opening overseas bank accounts must ensure they maintain documented proof of source of funds and file necessary regulatory reports.
Handling Notices and Prosecution Risk
If a taxpayer receives a notice related to Schedule FA:
- They should respond within the stipulated time with documentary evidence of ownership, value, and source of the asset.
- If disclosure was missed, a revised return may be filed (if within the permissible timeframe), or a compounding application may be considered in case of criminal exposure.
- Legal advice should be sought if prosecution under the Black Money Act or the Income Tax Act is initiated.
Ignoring a notice or providing incorrect replies can escalate the matter to seizure, prosecution, and travel restrictions.
Mitigating Penalties Through Voluntary Disclosure
While the 2015 compliance window is closed, voluntary and timely disclosure can still help mitigate penalties if caught. Timely correction in revised returns or voluntary declarations in ongoing assessments can reduce prosecutorial risks.
Taxpayers are advised to retain clear records of all foreign assets, tax-paid certificates, remittance documentation, and valuation reports.
Risk of Retrospective Action
The Black Money Act allows for prosecution even if foreign assets were acquired years ago but not disclosed in ITRs. The Act has retrospective powers and can penalize assets acquired before 2015 but discovered in later years.
This means dormant assets or ancestral accounts may still invite legal action if they have not been reported. Hence, taxpayers should not assume immunity based on the age of the asset or the absence of income generation.
Global Trends Influencing Schedule FA Enforcement
Globally, tax authorities are moving towards transparency and aggressive enforcement against offshore evasion:
- The U.S. enforces FATCA to monitor U.S. citizens’ foreign accounts, with harsh penalties.
- The U.K. has introduced Unexplained Wealth Orders to probe foreign property investments.
- The EU’s DAC6 regime focuses on cross-border tax planning structures.
India’s compliance and enforcement roadmap is gradually aligning with these international standards.
Importance of Record-Keeping and Yearly Reviews
Maintaining structured documentation is vital for compliance:
- Yearly account statements of all foreign accounts.
- Copies of contracts for overseas property purchases.
- Proof of funds used for acquiring assets abroad.
- Statements from foreign trusts or companies where an interest is held.
Taxpayers should review their foreign holdings each year before filing ITRs to ensure complete and accurate disclosure.
Conclusion
The obligation to disclose foreign assets under Schedule FA and the corresponding compliance requirements under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015, reflect India’s commitment to fighting offshore tax evasion and improving transparency. For resident taxpayers, the accurate reporting of overseas holdings is not merely a technical formality but a critical legal duty with far-reaching implications.
This compliance framework has been designed with the intent to track unreported foreign income and enforce severe consequences for willful concealment. The provisions governing Schedule FA demand that every individual assess their foreign financial interests in detail, whether it is an overseas bank account, investment in shares, ownership of property abroad, or signing authority in a foreign company. The emphasis on granular, jurisdiction-wise reporting compels residents to maintain meticulous records of their international financial dealings.
The Black Money Act operates independently of the Income-tax Act and introduces a stringent penalty and prosecution regime. The law presumes culpability in several cases, requiring taxpayers to prove that assets were disclosed or not taxable in India. Penalties for nondisclosure are substantial, and the risk of prosecution adds another layer of deterrence.
While Schedule FA applies only to resident and ordinarily resident individuals, those who have become residents after years of living abroad must remain particularly vigilant. Transitional years bring the added complexity of adjusting from non-resident to resident reporting obligations, and even minor errors in disclosure could invite scrutiny.
Voluntary compliance, especially during the early years of residency or after acquiring foreign assets, is key to avoiding the consequences laid out under the Black Money Act. Individuals with historical non-compliance can still consider filing updated returns under section 139(8A) or seeking legal remedies where bona fide errors have occurred.
Professional assistance in understanding treaty provisions, classification of ownership types, and cross-border tax rules becomes crucial when dealing with complex foreign holdings. As the Indian tax authorities deepen cooperation with other countries through the Common Reporting Standard and information exchange agreements, the detection of undisclosed foreign income and assets is no longer improbable.
Ultimately, Schedule FA and the Black Money Act serve as reminders of the importance of full and fair disclosure in a globally interconnected financial environment. Individuals must prioritize transparency, diligence, and timely reporting to remain compliant and uphold their legal responsibilities under India’s evolving tax framework.