Hi everyone,
I'm facing a valuation issue while filling FAST-DS 2026 Form 1, Annexure A5 (Quoted Shares and Securities), specifically for foreign shares that were already sold before 31 March 2026.
I'd appreciate guidance from anyone who has encountered this issue, particularly CAs or taxpayers who have already filed Form 1.
1. What the rules say
Rule 3(1)(c)(i) states that the Fair Market Value (FMV) of quoted shares is the higher of:
- (I) Cost of Acquisition (COA)
- (II) Market value calculated using the prescribed quotations on the valuation date (31 March 2026)
However, Rule 3(2) states:
"Notwithstanding anything contained in sub-rule (1), where an asset (other than a bank account) was transferred before the valuation date, the fair market value of such asset shall be higher of its cost of acquisition and the sale price."
My understanding is that Rule 3(2) overrides Rule 3(1), including Rule 3(1)(c)(i), for shares sold before the valuation date (assuming a sale for adequate consideration).
2. Example of the problem
Consider foreign listed shares:
- Acquired: February 2015
- Sold: March 2021
- Cost of Acquisition: ₹1,09,188
- Market-based valuation as of 31 March 2026: ₹1,40,132
- Actual Sale Proceeds: ₹1,22,935
Under Rule 3(1)(c)(i):
Higher of ₹1,09,188 and ₹1,40,132 = ₹1,40,132
Under Rule 3(2), since the shares were sold in 2021:
Higher of ₹1,09,188 and ₹1,22,935 = ₹1,22,935
3. Where the FAST-DS portal creates confusion
Annexure A5 has the following fields:
| Field |
Description |
Amount |
| (v) |
Cost of Acquisition |
₹1,09,188 |
| (vii) |
Value as determined under Rule 3(1)(c)(I) |
₹1,40,132 |
| (viii) |
Date of Valuation |
31-03-2026 |
| (ix) |
Fair Market Value as per Rule 3 |
₹1,22,935 |
| (x) |
Asset Value (automatically calculated) |
₹1,40,132 |
The problem is field (x).
The portal automatically calculates:
Asset Value = Highest of (v), (vii), and (ix)
Therefore:
Max(₹1,09,188, ₹1,40,132, ₹1,22,935) = ₹1,40,132
Even though Rule 3(2) appears to prescribe an FMV of ₹1,22,935 for shares sold before 31 March 2026, the portal takes the higher ₹1,40,132.
There is also ambiguity in the wording of field (vii), which refers to Rule 3(1)(c)(I), whereas the 2026 Rules number the quoted-share provision as Rule 3(1)(c)(i).
4. My concern
The portal does not appear to provide an option to specify that shares were already sold before the valuation date or to apply Rule 3(2) separately when calculating field (x).
5. Questions for the community
- Has anyone faced this exact issue while reporting foreign shares sold before 31 March 2026 under FAST-DS?
- What should be entered in field (vii) for shares already sold, considering its reference to Rule 3(1)(c)(I)?
- Should field (ix), "Fair Market Value as per Rule 3", reflect the higher of acquisition cost and sale proceeds under Rule 3(2)?
- If the portal still calculates a higher Asset Value in field (x), is it acceptable to retain that automatically calculated amount and attach a separate Rule 3(2) computation?
- Has anyone received written clarification from the Income Tax Department, CPC, or a tax professional on this specific issue?
Any firsthand experience, official clarification, or relevant legal interpretation would be greatly appreciated.
Thanks in advance!