ITR-6 for Foreign Owned Companies in 2026, Due Dates and Schedules

Written by CA Nandini, Krystal7 Consultants. Last updated 2 October 2026.

A foreign owned Indian company files ITR-6, the return for every company that does not claim exemption under section 11. For FY 2025-26 (AY 2026-27) it uses the ITR-6 notified under the Income Tax Act, 1961. The due date is 21 Nov 2026 after CBDT Circular No. 07/2026. A company that files a Form 3CEB transfer pricing report keeps 30 Nov 2026. The return must carry a digital signature.

This page covers the return, the dates and the schedules that foreign ownership triggers. It also covers the 22 percent regime, MAT credit, late filing costs and the move to the Income Tax Act, 2025. In the figures below, INR 1,00,000 is one lakh (100,000) and INR 1,00,00,000 is one crore (10 million).

Which return does a foreign owned company file?

ITR-6. Every company files it, except a company that claims exemption for income from property held for charitable or religious purposes under section 11. That company files ITR-7. A Private Limited company owned by a foreign parent is an Indian company, so it files ITR-6 as a domestic company.

The CBDT notified the AY 2026-27 version of ITR-6 through the Income Tax (Sixth Amendment) Rules, 2026. That is Notification No. 49/2026, G.S.R. 230(E) of 30 Mar 2026, in force from 31 Mar 2026. The notification replaces Form ITR-6 in the Income Tax Rules, 1962. Its opening words cite section 139 read with section 295 of the 1961 Act.

Foreign ownership does not make an Indian company a "foreign company" for tax. The company is incorporated in India, so ITR-6 Part A-GEN asks it to tick "Domestic Company". The foreign parent's ownership shows up in other fields, such as the holding company details and the shareholder schedules.

A company formed outside India with taxable Indian income also files ITR-6, but ticks "Foreign Company". This covers a branch office, a project office and a permanent establishment. The ITR-6 validation rules for AY 2026-27 block the 22 percent regime for a foreign company. Our guide to branch office rules in India explains when a branch is the better route.

Entity in India	Owner	Return for AY 2026-27	Company type in Part A-GEN	Notes
Private Limited company (wholly owned subsidiary)	Foreign parent company	ITR-6	Domestic Company	Must file even with a loss or no income
Private Limited company (joint venture)	Foreign and Indian shareholders	ITR-6	Domestic Company	Schedule SH-1 lists every shareholder
Branch office or project office	Foreign company	ITR-6	Foreign Company	Taxed at 35% plus surcharge and cess
Liaison office	Foreign company	Usually none; files Form 49C	Not applicable	A return is due only if the foreign company has taxable Indian income (our reading)
Foreign company with only dividend, interest, royalty or technical fees taxed at source	Foreign company	None, if section 115A(5) conditions hold	Not applicable	Tax must be withheld at the section 115A rate, not a treaty rate
LLP with a foreign partner	Foreign partner	ITR-5	Not applicable	ITR-6 is for companies only

Sources: ITR-6 for AY 2026-27 (Notification No. 49/2026); ITR-6 validation rules version 1.0; section 139(1) of the Income Tax Act, 1961; section 207(8) of the Income Tax Act, 2025.

A company must file whatever its income. Section 139(1) says every person "being a company or a firm" shall furnish a return. There is no threshold, so a dormant or loss making subsidiary still files ITR-6.

What is the ITR-6 due date for AY 2026-27?

For a company without a transfer pricing report, the due date is 21 Nov 2026. CBDT Circular No. 07/2026 of 28 Sep 2026 extended it from 31 Oct 2026. A company that must file Form 3CEB under section 92E keeps 30 Nov 2026. The circular did not change that date.

The base dates sit in Explanation 2 to section 139(1) of the 1961 Act. The table there gives 30 Nov to an assessee that must file a report under section 92E. It gives 31 Oct to a company that is not in that row.

Circular No. 07/2026 (F. No. 225/128/2026/ITA-II) relies on section 119 of the 1961 Act read with section 536 of the 2025 Act. It covers persons in serial 2 of the Explanation 2 table. That row holds companies and audited assessees to whom section 92E does not apply. The tax audit report date for the same group moved from 30 Sep 2026 to 21 Oct 2026.

The income tax portal posted the extension on 29 Sep 2026.

Most foreign owned subsidiaries fall in the 30 Nov group. A single transaction with the parent, such as a service fee, a cost recharge, a loan or a guarantee, is an international transaction. That brings Form 3CEB and the later date. Our guide to Form 3CEB applicability and due dates covers the test.

Filing for FY 2025-26 (AY 2026-27)	No transfer pricing report	With a Form 3CEB transfer pricing report	Provision
Tax audit report, Forms 3CA and 3CD	21 Oct 2026 (was 30 Sep 2026)	31 Oct 2026	Section 44AB; Circular No. 07/2026
MAT report, Form 29B	21 Oct 2026 (follows the tax audit date)	31 Oct 2026	Section 115JB
Transfer pricing report, Form 3CEB	Not applicable	31 Oct 2026	Section 92E
Option for 22 percent regime, Form 10-IC	21 Nov 2026 (our reading; 31 Oct 2026 is the cautious date)	30 Nov 2026	Section 115BAA(5)
ITR-6	21 Nov 2026 (was 31 Oct 2026)	30 Nov 2026	Section 139(1); Circular No. 07/2026
Belated ITR-6	31 Dec 2026	31 Dec 2026	Section 139(4); transition FAQ Q3.8
Revised ITR-6	31 Mar 2027 (fee after 31 Dec 2026)	31 Mar 2027 (fee after 31 Dec 2026)	Sections 139(5) and 234-I
Foreign tax credit statement, Form 67	31 Mar 2027	31 Mar 2027	Rule 128(9)

Sources: section 139 of the Income Tax Act, 1961 as amended by the Finance Act, 2026; CBDT Circular No. 07/2026; CBDT transition FAQs Q3.7 and Q3.8; section 115JB of the Income Tax Act, 1961 for Form 29B.

The extension moves only the return date and the audit report date. Interest for short advance tax under sections 234B and 234C does not depend on the return date. We pay any self assessment tax as soon as the computation is final, and before the original date where we can.

The portal opened ITR-6 for AY 2026-27 late in the season. Online filing of ITR-6 opened on 18 Aug 2026, and the offline utility followed on 20 Aug 2026 (income tax portal news). The Excel utility, JSON schema and validation rules version 1.0 are on the portal's downloads page.

Which ITR-6 schedules matter for foreign owned companies?

Five areas carry the foreign ownership questions. Part A-GEN asks about holding companies and beneficial owners. Schedule SH-1 and Schedule AL-1 apply to unlisted companies. Schedule FA covers foreign assets. Schedule TPSA covers transfer pricing secondary adjustments. Schedules FSI and TR cover foreign income and the credit for foreign tax.

The AY 2026-27 JSON schema lists the schedules of ITR-6. Beside the usual income schedules, it includes ScheduleSH, ScheduleAL, ScheduleFA, ScheduleFD, ScheduleTPSA, ScheduleMAT, ScheduleMATC, ScheduleFSI, ScheduleTR1 and ScheduleGST.

Part A-GEN, the ownership questions

The AY 2026-27 form asks the "Type of company", with a choice of domestic or foreign company. It asks the "Nature of company", which can be holding company, subsidiary company, both or other. A subsidiary must give the details of its holding company.

The form also asks for the beneficial owners of shares with at least 10 percent of the voting power. The wording is "Particulars of persons who were beneficial owners of shares holding not less than 10% of the voting power at any time of the previous year". For an unlisted company, it asks for the natural persons who were the ultimate beneficial owners at the same 10 percent level. A foreign parent's own owners can therefore appear in an Indian return.

Other Part A-GEN items that matter to a subsidiary:

1. Whether the company has opted for section 115BA, 115BAA or 115BAB. If so, the year of first option and the Form 10-IC filing date.
2. "Are you liable for Audit u/s 92E?", which ties the return to Form 3CEB.
3. Whether the company exercises the option under section 92CE(2A), which triggers Schedule TPSA.
4. Whether DPIIT recognises the company as a start up.
5. The Legal Entity Identifier (LEI), "mandatory if refund is 50 Crores or more".

Schedule SH-1 and Schedule AL-1

An unlisted company fills Schedule SH-1 with its shareholding and Schedule AL-1 with its assets and liabilities at year end. Part A-BS of the form tells unlisted companies to "fill up the Schedule SH-1 and Schedule AL-1". A recognised start up fills Schedule SH-2 and Schedule AL-2 instead.

Schedule SH-1 has three parts, as the department's Schedule SH-1 page describes. The first lists each shareholder at year end by name, residential status, type of shares and PAN. It also takes the date of allotment, number of shares held, face value, issue price and amount received. The second covers share application money pending allotment. It takes the applicant, shares applied for, money received and proposed issue price. The third covers persons who stopped being shareholders in the year, with the date and mode of cessation. The residential status column shows a foreign parent as a non resident.

We reconcile Schedule SH-1 against three documents. They are the register of members, the FC-GPR or FC-TRS filings, and the audited share capital note. A share allotment in March that missed its FC-GPR shows up as a mismatch here. Our guide on the FC-GPR 30 day deadline explains that filing.

Schedule FA and the foreign asset rule

Schedule FA lists foreign assets held by a resident. An Indian subsidiary is resident, so it reports any foreign bank account, overseas subsidiary or other asset outside India. A subsidiary that made an overseas investment under the ODI rules must report that holding here.

Schedule FA runs on the calendar year, not the financial year. The AY 2026-27 form words the period as "the calendar year ending as on 31st December, 2025". A company with a March year end therefore reports its foreign assets for January to December 2025.

Leaving an asset out of Schedule FA has its own penalty. Section 43 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 levies INR 10,00,000. The Finance (No. 2) Act, 2024 added an exemption from 1 Oct 2024. The penalty does not apply to assets, other than immovable property, worth up to INR 20,00,000 in total. Our guide to ODI annual performance reports covers the FEMA side of an overseas holding.

Schedules FSI, TR and Form 67

An Indian subsidiary that earns fees abroad often suffers foreign withholding tax. Schedule FSI reports the foreign income country by country. Schedule TR claims the relief for tax paid outside India. The claim needs Form 67 under rule 128, which is due by 31 Mar 2027 for AY 2026-27. Our guide to foreign tax credit and Form 67 covers the computation.

Schedule TPSA, Schedule MAT and Schedule MATC

Schedule TPSA applies when a transfer pricing adjustment calls for a secondary adjustment under section 92CE. Where the parent does not return the excess money in time, the company may opt under section 92CE(2A) to pay tax on it. Schedule MAT computes tax on book profit under section 115JB. Schedule MATC tracks MAT credit carried forward.

Schedule or part	What it reports	When a foreign owned company fills it	Common source of error
Part A-GEN	Company type, holding company, 10% beneficial owners, regime option, 92E status, LEI	Always	Holding company details left blank or ticked as "Foreign Company"
Schedule SH-1	Shareholders, allotments, share application money, exits	Unlisted company that is not a recognised start up	Mismatch with FC-GPR and the share capital note
Schedule SH-2	Shareholding of a start up	DPIIT recognised start up	Filled when the company is not recognised
Schedule AL-1	Assets and liabilities at year end	Unlisted company that is not a recognised start up	Loans to the parent or group left out
Schedule FA	Foreign bank accounts, equity and other assets outside India	Resident company with any foreign asset	Overseas subsidiary or foreign bank account missing
Schedules FSI and TR	Foreign source income and foreign tax relief	Company with foreign withholding tax	No Form 67, so credit is denied
Schedule TPSA	Secondary adjustment under section 92CE(2A)	Company that opts to pay tax on unrepatriated excess money	Option exercised without the schedule
Schedule MAT and MATC	Book profit tax and MAT credit	Company in the normal regime	Credit carried after a section 115BAA option
Schedule GST	Turnover as per GST returns	Every GST registered company	Turnover mismatch with the profit and loss account

Sources: ITR-6 for AY 2026-27, Part A-GEN, Part A-BS and Schedule FA; Income Tax Department page on Schedule SH-1; ITR-6 JSON schema version 1.0; ITR-6 validation rules version 1.0; section 43 of the Black Money Act, 2015.

Who signs ITR-6 and how is it filed?

The managing director verifies the return. If the managing director cannot, or there is none, any director verifies it. For a company not resident in India, a person holding a valid power of attorney may verify it, and the power of attorney is attached. The verification must use a digital signature certificate (DSC).

These rules come from section 140 of the 1961 Act, as the department's "Return of income" page states. The income tax portal's DSC FAQ says a DSC is mandatory for e verification of returns filed by companies. The signatory registers the DSC on the portal before filing. Aadhaar OTP and net banking verification are not open to a company.

A foreign owned subsidiary often has no director resident in India with a DSC. Each Indian DSC needs identity checks, and foreign directors need apostilled documents. We start the DSC early in September so that a signatory is ready before the date.

Should the company opt for the 22 percent regime?

Opt for section 115BAA when the company has little or no MAT credit and does not rely on the excluded deductions. The rate is 22 percent plus a flat 10 percent surcharge and 4 percent cess, an effective 25.168 percent. MAT does not apply. A company with large MAT credit may pay less by staying in the normal regime for FY 2025-26.

Section 115BAA of the 1961 Act lets a domestic company pay tax at 22 percent if it gives up certain deductions. The excluded items include SEZ deductions under section 10AA, additional depreciation, and most Chapter VI-A deductions except sections 80JJAA and 80M. Losses and depreciation carried forward that arise from those deductions cannot be set off.

The company opts by filing Form 10-IC on or before the due date under section 139(1). For AY 2026-27 that is 21 Nov 2026, or 30 Nov 2026 in a transfer pricing case. The 21 Nov 2026 date is our reading. Circular No. 07/2026 extends the return date, and section 115BAA(5) points to that date. A cautious company without Form 3CEB files Form 10-IC by 31 Oct 2026. Section 115BAA(5) says the option, once exercised, "cannot be subsequently withdrawn for the same or any other previous year". A company that misses the date pays the normal rate for that year.

The AY 2026-27 rates come from the department's tax rates page. A domestic company whose turnover or gross receipts in 2023-24 did not exceed INR 400 crore pays 25 percent. Any other domestic company pays 30 percent. Surcharge is 7 percent above INR 1 crore of income and 12 percent above INR 10 crore. A foreign company pays 35 percent, with 2 and 5 percent surcharge.

Regime for AY 2026-27	Base rate	Surcharge: income up to INR 1 crore	Surcharge: INR 1 crore to INR 10 crore	Surcharge: above INR 10 crore	Effective rate in each band, with 4% cess
Domestic company, 2023-24 turnover up to INR 400 crore	25%	Nil	7%	12%	26.000% / 27.820% / 29.120%
Other domestic company	30%	Nil	7%	12%	31.200% / 33.384% / 34.944%
Section 115BAA	22%	10%	10%	10%	25.168% in every band
MAT on book profit, normal regime	15%	Nil	7%	12%	15.600% / 16.692% / 17.472%
Foreign company (branch or PE)	35%	Nil	2%	5%	36.400% / 37.128% / 38.220%

Sources: Income Tax Department, tax rates for AY 2026-27; sections 115BAA and 115JB of the Income Tax Act, 1961. Effective rates are our arithmetic and ignore marginal relief.

The MAT credit question

MAT credit decides the choice for many subsidiaries. Under the 1961 Act, a company that opts for section 115BAA can no longer use MAT credit built up in earlier years. A company in the normal regime can set off the credit in a year when normal tax exceeds MAT, up to that difference. The credit carries forward for 15 years.

The Finance Act, 2026 changed this from tax year 2026-27. The Budget 2026 FAQs say a domestic company in the old regime "cannot" set off accumulated MAT credit. It can use the credit only after it moves to the new regime from tax year 2026-27. The set off is capped at 25 percent of the tax for the year. MAT in the old regime falls to 14 percent and becomes a final tax with no new credit.

So FY 2025-26 is the last year in which an old regime company can set off MAT credit under the normal provisions. We run both computations for every subsidiary that carries MAT credit before the Form 10-IC date. The worked example below shows the arithmetic.

What changes from tax year 2026-27 under the Income Tax Act, 2025?

FY 2026-27 is "tax year 2026-27" under section 3 of the Income Tax Act, 2025, and its return is filed in 2027. Section 263 replaces section 139. The due dates stay at 31 Oct 2027 for a company and 30 Nov 2027 with a Form 48 transfer pricing report. CBDT has not notified the new return forms as of 2 Oct 2026.

The CBDT transition FAQs draw the line clearly. Q3.6 and Q3.11 say AY 2026-27 uses the ITR forms under the 1961 Act. Q4.39 says the portal will support old forms for AY 2026-27 and earlier and new forms from tax year 2026-27. The portal's returns help page says the new forms "will be notified by the Government well before the due dates".

Section 263(1) of the 2025 Act requires a company to file "regardless of income or loss". The table in section 263(1)(c) gives a company 31 Oct and a person with a section 172 report 30 Nov. Section 172 is the successor to section 92E, and Form 48 replaces Form 3CEB.

The 22 percent regime moves to section 200 of the 2025 Act. It keeps the 22 percent rate, the excluded deductions and the rule that the option "shall not be subsequently withdrawn". The option is exercised "in such manner as may be prescribed on or before the due date specified under section 263(1)". Section 536(2)(f) keeps alive an option already exercised under section 115BAA.

The department's old to new form map lists no successor to Form 10-IC as of 2 Oct 2026. A company making a fresh section 200 option for tax year 2026-27 should check the income tax portal for the prescribed form or manner. It should do so well before the section 263(1) due date.

Item	Income Tax Act, 1961 (AY 2026-27)	Income Tax Act, 2025 (tax year 2026-27)
Year concept	Previous year 2025-26, assessment year 2026-27	Tax year 2026-27 (section 3)
Duty to file a return	Section 139(1)	Section 263(1)
Due date table	Explanation 2 to section 139(1)	Section 263(1)(c)
Return form for a company	ITR-6, Notification No. 49/2026	New form under the Income Tax Rules, 2026, not yet notified
Belated return	Section 139(4), by 31 Dec 2026	Section 263(4), nine months from the end of the tax year
Revised return	Section 139(5), by 31 Mar 2027	Section 263(5), twelve months from the end of the tax year (Finance Act, 2026)
Updated return	Section 139(8A)	Section 263(6)
Who verifies	Section 140	Section 265
Late return fee	Section 234F	Section 428(a)
Late revised return fee	Section 234-I	Section 428(b)
22 percent regime	Section 115BAA, Form 10-IC	Section 200; check the portal for the option form or manner
MAT	Section 115JB, 15%, Form 29B	Section 206, 14%, Form 66
Transfer pricing report	Section 92E, Form 3CEB	Section 172, Form 48
Tax audit report	Section 44AB, Forms 3CA and 3CD	Section 63, Form 26
Foreign tax credit statement	Rule 128, Form 67	Rule 76, Form 44
Foreign company special rates	Section 115A	Section 207

Sources: Income Tax Act, 2025 sections 3, 63, 172, 200, 206, 207, 263, 265 and 428; CBDT transition FAQs; official form map on incometaxindia.gov.in; Budget 2026 FAQs.

Our overview of Income Tax Act, 2025 changes for foreign owned companies covers the wider renumbering.

What happens if the return is filed late?

A company that misses the due date can still file a belated return by 31 Dec 2026 for AY 2026-27. It pays a fee of INR 5,000 under section 234F, or INR 1,000 if total income is up to INR 5,00,000. Interest runs at 1 percent a month under section 234A. A business loss for the year cannot be carried forward.

Section 139(4) allows the belated return until three months before the end of the assessment year. CBDT transition FAQ Q3.8 confirms 31 Dec 2026 for AY 2026-27. After that date, the only route is an updated return under section 139(8A). It carries additional tax of 25 to 70 percent of the tax and interest, depending on the delay.

Section 234A charges interest at 1 percent for each month or part of a month. It runs from the day after the due date to the date of filing. It applies to the tax on total income less advance tax, TDS and other prepaid taxes.

The loss rule hurts start up subsidiaries most. Section 139(3) with section 80 lets a company carry forward a business loss only if it filed by the section 139(1) due date. Unabsorbed depreciation survives a late return, but the business loss does not. The department's return of income page confirms that a late filer loses the loss, other than house property loss.

A late filer can also lose the regime option. Form 10-IC is due by the section 139(1) date. A company that has not filed Form 10-IC by then cannot start the section 115BAA option for that year. A company that opted in an earlier year keeps its option.

Consequence of a late ITR-6	AY 2026-27 rule (1961 Act)	Amount or effect	Tax year 2026-27 rule (2025 Act)
Late filing fee	Section 234F	INR 5,000; INR 1,000 if total income up to INR 5,00,000	Section 428(a), same amounts
Interest on unpaid tax	Section 234A	1% a month or part, from the day after the due date	Successor section not mapped on this page
Business loss of the year	Sections 139(3) and 80	Not carried forward	Same rule continues (transition FAQ Q3.21 on old losses)
First time section 115BAA option	Section 115BAA(5)	Lost for that year if Form 10-IC is also late	Section 200, due by the section 263(1) date
Revised return after 31 Dec 2026	Section 234-I	INR 5,000; INR 1,000 if total income up to INR 5,00,000	Section 428(b), same amounts
No return by 31 Dec 2026	Section 139(8A)	Updated return with 25% to 70% additional tax	Section 263(6)

Sources: sections 139, 234A, 234F and 234-I of the Income Tax Act, 1961; section 428 of the Income Tax Act, 2025; Budget 2026 FAQs on updated returns; CBDT transition FAQs Q3.7 to Q3.9.

Can ITR-6 be revised after filing?

Yes. For AY 2026-27 a company can revise ITR-6 until 31 Mar 2027 or the completion of assessment, whichever is earlier. The Finance Act, 2026 extended the window. A revision filed after 31 Dec 2026 attracts a fee under the new section 234-I. The fee is INR 5,000, or INR 1,000 if total income is up to INR 5,00,000.

Section 139(5) now reads "at any time before the end of the relevant assessment year or before the completion of the assessment". Section 234-I was inserted by Act No. 4 of 2026 with effect from 1 Mar 2026. CBDT transition FAQ Q3.7 confirms the 31 Mar 2027 date for AY 2026-27.

A revision does not reopen the regime option. If the company missed Form 10-IC by the due date, a revised return cannot add the section 115BAA option for that year. We fix option errors before the original return.

Does the foreign parent file its own Indian return?

Usually not, if its only Indian income is dividend, interest, royalty or fees for technical services taxed at source. Section 115A(5) of the 1961 Act excuses a foreign company from filing when tax was deducted at the section 115A rates. A parent that claimed a lower treaty rate does not get this relief.

From tax year 2026-27, section 207(8) of the 2025 Act carries the same exemption. It applies only if tax was withheld at the section 207 rate. A parent taxed at a treaty rate on dividends or service fees should expect to file its own Indian return. That return is ITR-6, filed as a foreign company.

The subsidiary's withholding drives the parent's filing. Our guides on TDS on payments to non residents and dividends from an Indian subsidiary to a foreign parent cover the rates.

How do Form 3CEB and the master file link to ITR-6?

ITR-6 asks whether the company is liable for audit under section 92E. A "Yes" moves the due date to 30 Nov 2026 and requires Form 3CEB by 31 Oct 2026. The return's figures for related party payments must match Form 3CEB and Form 3CD.

Form 3CEB is filed by a chartered accountant and accepted by the company on the portal before the return. A subsidiary that is part of a large group may also need the master file in Form 3CEAA. From tax year 2026-27 the master file is Form 56 under the 2025 Act. Our guide to master file and CbCR requirements gives the thresholds.

We check three numbers across the forms before filing. They are the total of international transactions, the amount of any transfer pricing adjustment, and TDS deducted on payments to the parent. A gap between Form 3CEB and Schedule BP is a common reason for a notice.

What documents does the company need for ITR-6?

The return rests on the audited financial statements and the tax audit report. A foreign owned subsidiary also needs its FEMA filings, transfer pricing report, TDS records for foreign payments and any foreign tax certificates. We collect these by the tax audit date, so the return is a matching exercise.

Document	Used for	Owner of the document	Due or ready by (AY 2026-27)
Audited balance sheet and profit and loss account	Part A-BS, Part A-P&L, Schedule MAT	Statutory auditor	Before the tax audit report
Forms 3CA and 3CD	Disallowances, TDS defaults, loans, depreciation	Tax auditor	21 Oct 2026 or 31 Oct 2026
Form 3CEB	International transactions, Part A-GEN 92E question	Chartered accountant	31 Oct 2026
Form 29B	Book profit under section 115JB	Chartered accountant	Tax audit date
Register of members, FC-GPR and FC-TRS acknowledgements	Schedule SH-1, Part A-GEN beneficial owners	Company secretary	Before filing
Form 26AS and annual information statement	TDS and TCS credit, Schedule TDS2	Income tax portal	Download before filing
Form 27Q statements and Form 15CA and 15CB copies	Payments to the parent and other non residents	Company and accountant	Quarterly
Foreign withholding certificates and Form 67	Schedules FSI and TR	Company and chartered accountant	31 Mar 2027
Form 10-IC acknowledgement	Section 115BAA option in Part A-GEN	Company	By the return due date
DSC of the managing director or a director	Verification	Signatory	Registered before filing

Sources: ITR-6 for AY 2026-27; sections 44AB, 92E, 115JB, 115BAA and 140 of the Income Tax Act, 1961; rule 128 of the Income Tax Rules, 1962.

Our compliance calendar for foreign owned companies places these dates alongside the MCA and FEMA filings.

What changed in 2026

Three changes in 2026 affect the AY 2026-27 return directly. CBDT moved the date for non transfer pricing companies. The Finance Act, 2026 lengthened the revised return window and added a fee. The Income Tax Act, 2025 started on 1 Apr 2026 and changed the MAT credit rules from tax year 2026-27.

Change	Old rule	New rule	Date	Instrument
ITR-6 form for AY 2026-27	Previous ITR-6	New ITR-6 substituted	In force 31 Mar 2026	Income Tax (Sixth Amendment) Rules, 2026, G.S.R. 230(E), Notification No. 49/2026
Return date, company without Form 3CEB	31 Oct 2026	21 Nov 2026	Circular dated 28 Sep 2026	CBDT Circular No. 07/2026
Tax audit report date, same group	30 Sep 2026	21 Oct 2026	Circular dated 28 Sep 2026	CBDT Circular No. 07/2026
Revised return window	Before 31 Dec of the assessment year	Before the end of the assessment year (31 Mar 2027)	1 Mar 2026	Finance Act, 2026 (Act No. 4 of 2026), section 139(5)
Fee on a late revised return	None	INR 5,000, or INR 1,000 up to INR 5,00,000 income	1 Mar 2026	Section 234-I inserted by Act No. 4 of 2026
Governing Act for FY 2026-27 income	Income Tax Act, 1961	Income Tax Act, 2025	1 Apr 2026	Act 30 of 2025
MAT rate, old regime	15%	14%, final tax, no new credit	Tax year 2026-27	Finance Act, 2026; Budget 2026 FAQs
MAT credit for a domestic company	Set off in the normal regime	Set off only after moving to section 200 or 201, capped at 25% of tax	Tax year 2026-27	Finance Act, 2026; Budget 2026 FAQs
Revised return under the 2025 Act	Nine months from the end of the tax year	Twelve months, with a fee after nine months	1 Apr 2026	Finance Act, 2026; section 428(b)

Sources: Notification No. 49/2026; CBDT Circular No. 07/2026; sections 139 and 234-I of the Income Tax Act, 1961; Budget 2026 FAQs; Income Tax Department MAT and AMT page.

Worked example

Two hypothetical subsidiaries show how the dates, the regime choice and the late filing rules combine. Neither is a client. Both use FY 2025-26 rates.

TechCo India Private Limited, a US subsidiary with MAT credit

TechCo India Private Limited is wholly owned by a Delaware parent. It earned INR 30 crore of revenue in 2023-24, so the 25 percent rate applies. It provides software development services to the parent and files Form 3CEB. Its ITR-6 is due on 30 Nov 2026.

For FY 2025-26, taxable income is INR 2,40,00,000 and book profit is INR 2,50,00,000. TechCo claims no deduction that section 115BAA would deny. It carries MAT credit of INR 35,00,000 from earlier years.

Step	Normal regime (INR)	Section 115BAA (INR)
Taxable income	2,40,00,000	2,40,00,000
Tax at 25% or 22%	60,00,000	52,80,000
Surcharge at 7% or 10%	4,20,000	5,28,000
Cess at 4%	2,56,800	2,32,320
Tax before MAT credit	66,76,800	60,40,320
MAT on book profit of 2,50,00,000 (15% + 7% + 4%)	41,73,000	Not applicable
MAT credit usable (normal tax less MAT)	25,03,800	Not available
Tax payable	41,73,000	60,40,320
MAT credit left at year end	9,96,200	Lost

The normal regime saves TechCo INR 18,67,320 for FY 2025-26. It should not file Form 10-IC for AY 2026-27. The usable credit is INR 66,76,800 less INR 41,73,000, which is INR 25,03,800.

From tax year 2026-27, TechCo cannot use the remaining INR 9,96,200 if it stays in the old regime. If it moves to section 200, it can set off credit up to 25 percent of its tax. As an illustration only, assume the same income and a tax of INR 60,40,320. The cap is INR 15,10,080, so the full INR 9,96,200 is usable, and the tax falls to INR 50,44,120. We would confirm the tax year 2026-27 rates before relying on this.

BuildCo India Private Limited, a Singapore subsidiary that files late

BuildCo India Private Limited is owned by a Singapore parent and also files Form 3CEB. Its due date is 30 Nov 2026. The directors sign the accounts late, and BuildCo files ITR-6 on 20 Dec 2026.

In case A, BuildCo has taxable income of INR 80,00,000. On 30 Nov 2026 it still owes self assessment tax of INR 6,00,000. Interest under section 234A runs from 1 Dec 2026 to 20 Dec 2026. That is part of one month, so interest is 1 percent of INR 6,00,000, which is INR 6,000. The fee under section 234F is INR 5,000, because total income exceeds INR 5,00,000. The extra cost is INR 11,000, plus any section 234B and 234C interest.

In case B, BuildCo has a business loss of INR 1,20,00,000 and no tax to pay. Interest is nil. The section 234F fee is INR 1,000, because total income does not exceed INR 5,00,000. The larger cost is the loss. BuildCo cannot carry forward the INR 1,20,00,000 business loss, though unabsorbed depreciation still carries.

Common mistakes

1. Ticking "Foreign Company" for an Indian subsidiary. The company is incorporated in India, so it is a domestic company. Fix: tick "Domestic Company" and give the parent in the holding company details.
2. Working to 21 Nov 2026 when Form 3CEB applies. A company with any international transaction keeps 31 Oct 2026 for Form 3CEB. Its ITR-6 stays due on 30 Nov 2026. Fix: decide the section 92E position in August.
3. Filing Form 10-IC without checking MAT credit. The option cannot be withdrawn, and the MAT credit stops being usable under the 1961 Act. Fix: compute both regimes, as in the TechCo example, before the due date.
4. Schedule SH-1 that does not match FEMA records. Allotment dates, issue prices and amounts must agree with the FC-GPR filings. They must also agree with the share capital note. Fix: reconcile the three before filing.
5. Leaving an overseas holding out of Schedule FA. The Black Money Act penalty is INR 10,00,000. The INR 20,00,000 exemption excludes immovable property. Fix: list every foreign account and investment, including an ODI subsidiary.
6. No Form 67 for foreign withholding. Without it, the credit claimed in Schedule TR fails. Fix: file Form 67 with the return, and in any case by 31 Mar 2027.
7. No DSC for any director in India. The signatory cannot verify the return without one. Fix: get and register a DSC for the managing director or a director in September.
8. Assuming the parent never files. A parent that took a treaty rate loses the section 115A(5) exemption. Fix: check the rate used on every remittance to the parent.
9. Missing the belated date for a loss year. After 31 Dec 2026 only an updated return is possible, and the loss is already lost. Fix: file a loss return by the due date, even if the accounts are simple.

ITR-6 checklist for a foreign owned company

1. Confirm whether the company had any international transaction in FY 2025-26, and fix the due date at 21 Nov 2026 or 30 Nov 2026.
2. Finalise the audited financial statements and get Forms 3CA and 3CD by 21 Oct 2026 or 31 Oct 2026.
3. File Form 3CEB by 31 Oct 2026 if section 92E applies, and have the company accept it on the portal.
4. Get Form 29B for the MAT computation by the tax audit date, unless the company is under section 115BAA.
5. Compute tax under both regimes and decide on Form 10-IC, taking MAT credit into account.
6. Reconcile Schedule SH-1 with the register of members, FC-GPR and FC-TRS filings and the share capital note.
7. List all foreign bank accounts and overseas investments for Schedule FA.
8. Match TDS and TCS credits with Form 26AS and the annual information statement.
9. Prepare Schedules FSI and TR, and file Form 67 for any foreign tax withheld.
10. Register the DSC of the managing director or a director on the income tax portal.
11. Pay self assessment tax, then file ITR-6 with the DSC before the due date.
12. Save the acknowledgement and check the return processing intimation for mismatches.

To have us run this checklist for your subsidiary, write to [email protected] or see our income tax return service.

Frequently Asked Questions

Is ITR-6 mandatory for a Private Limited company with no income?+

Yes. Section 139(1) of the Income Tax Act, 1961 requires every company to file a return, whatever its income or loss. A dormant or pre revenue subsidiary files a nil or loss ITR-6 for AY 2026-27. From tax year 2026-27, section 263(1) of the Income Tax Act, 2025 keeps the rule, requiring a company to file "regardless of income or loss".

What is the ITR-6 due date for AY 2026-27 after the CBDT extension?+

21 Nov 2026 for a company that does not file a Form 3CEB transfer pricing report. CBDT Circular No. 07/2026 of 28 Sep 2026 moved it from 31 Oct 2026. A company that files Form 3CEB under section 92E keeps 30 Nov 2026. The circular also moved the tax audit report date for the first group to 21 Oct 2026.

Does a foreign owned subsidiary fill ITR-6 as a foreign company?+

No. A company incorporated in India is a domestic company, even if a foreign parent owns all its shares. It ticks "Domestic Company" in Part A-GEN of ITR-6 and gives the parent's details as the holding company. Only a company formed outside India, such as one with an Indian branch or project office, ticks "Foreign Company".

Can a foreign company with an Indian branch opt for the 22 percent rate?+

No. Section 115BAA of the 1961 Act and section 200 of the 2025 Act apply only to domestic companies. The ITR-6 validation rules for AY 2026-27 block the option when the company type is "Foreign Company". A branch pays 35 percent plus surcharge of 2 or 5 percent and 4 percent cess for AY 2026-27.

When must Form 10-IC be filed for AY 2026-27?+

On or before the section 139(1) due date for the return. That is 30 Nov 2026 for a company with a Form 3CEB report. For a company without one it is 21 Nov 2026, on our reading of Circular No. 07/2026. Filing by 31 Oct 2026 removes any doubt. Section 115BAA(5) says the option cannot be withdrawn for that or any later year. A company that misses the date pays the normal rate for AY 2026-27.

Which ITR-6 schedule shows the foreign parent's shareholding?+

Schedule SH-1, for an unlisted company that is not a DPIIT recognised start up. It lists each shareholder with residential status, PAN, allotment details and amounts received. Part A-GEN separately asks for persons holding at least 10 percent of the voting power and, for an unlisted company, the natural persons who are ultimate beneficial owners at that level.

Does an Indian subsidiary need to fill Schedule FA?+

Yes, if it holds any asset outside India, such as a foreign bank account or shares in an overseas subsidiary. Schedule FA applies to residents, and an Indian company is resident. Section 43 of the Black Money Act, 2015 levies INR 10,00,000 for leaving an asset out, except assets other than immovable property worth up to INR 20,00,000 in total.

Can ITR-6 be verified with Aadhaar OTP?+

No. A company must verify ITR-6 with a digital signature certificate. The income tax portal's DSC FAQ says a DSC is mandatory for e verification of returns filed by companies. The signatory is the managing director, or any director where there is no managing director. A non resident company may use a person holding its power of attorney.

What is the late fee for filing ITR-6 after the due date?+

INR 5,000 under section 234F of the 1961 Act, or INR 1,000 where total income does not exceed INR 5,00,000. Interest at 1 percent a month also runs under section 234A on unpaid tax. From tax year 2026-27, section 428(a) of the Income Tax Act, 2025 charges the same fee amounts.

What is the last date for a belated ITR-6 for AY 2026-27?+

31 Dec 2026, or the completion of assessment if earlier. CBDT transition FAQ Q3.8 confirms this under section 139(4) of the 1961 Act. After 31 Dec 2026, the company can only file an updated return under section 139(8A). That return carries additional tax of 25 to 70 percent of the tax and interest.

Can a company carry forward a loss if ITR-6 is filed late?+

No, for a business loss. Section 139(3) read with section 80 allows carry forward only if the return was filed by the section 139(1) due date. Unabsorbed depreciation still carries forward. For AY 2026-27 that means filing by 21 Nov 2026, or 30 Nov 2026 where Form 3CEB applies.

Will the CBDT extension also apply to tax year 2026-27?+

No. CBDT Circular No. 07/2026 covers AY 2026-27 only. For tax year 2026-27, section 263(1)(c) of the Income Tax Act, 2025 sets 31 Oct 2027 for a company and 30 Nov 2027 where a section 172 report in Form 48 is due. Any extension for 2027 would need a new circular.

Which return form will a company use for tax year 2026-27?+

A new return form under the Income Tax Rules, 2026, which CBDT had not notified on 2 Oct 2026. The income tax portal says the new forms will be notified well before the due dates. CBDT transition FAQ Q4.39 says the portal will run the old forms for AY 2026-27 and the new forms from tax year 2026-27 side by side.

Does a foreign parent receiving dividends need to file an Indian return?+

Not if its only Indian income is dividend, interest, royalty or technical fees taxed at source at the section 115A rates. Section 115A(5) of the 1961 Act gives that exemption. Section 207(8) of the 2025 Act carries it forward from tax year 2026-27. A parent taxed at a lower treaty rate does not qualify and should file.

What happens to MAT credit if the company stays in the old regime from tax year 2026-27?+

It cannot be set off. The Budget 2026 FAQs say a domestic company in the old regime cannot use accumulated MAT credit. The company can use it only after moving to section 200 or 201, capped at 25 percent of the tax for the year. MAT in the old regime falls to 14 percent and becomes a final tax.

How many times can ITR-6 be revised for AY 2026-27?+

Section 139(5) of the 1961 Act sets no limit on the number of revisions. The deadline is 31 Mar 2027 or completion of assessment, if earlier. A revision filed after 31 Dec 2026 carries a section 234-I fee of INR 5,000, or INR 1,000 where total income is up to INR 5,00,000. Each revised return replaces the earlier one.

Sources

• CBDT, Notification No. 49/2026, Income Tax (Sixth Amendment) Rules, 2026, G.S.R. 230(E), 30 Mar 2026 (Form ITR-6 for AY 2026-27), https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-04/Notification%20No.49_2026.pdf
• Income Tax Department, Form ITR-6 Indian Income Tax Return (AY 2026-27), read 2 Oct 2026, https://www.incometaxindia.gov.in/documents/d/guest/itr-6-2026-eng-1-pdf
• Income Tax Department, ITR-6 JSON schema version 1.0, AY 2026-27, read 2 Oct 2026, https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-08/ITR-6_2026_Main_V1.0.json
• Income Tax Department, ITR-6 validation rules version 1.0, AY 2026-27, read 2 Oct 2026, https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-08/CBDT__e-Filing_ITR-6_Validation%20Rules_Version%201.0_AY%202026-27.pdf
• Income Tax Department, income tax portal downloads page (ITR-6 utilities), read 2 Oct 2026, https://www.incometax.gov.in/iec/foportal/downloads
• Income Tax Department, income tax portal news (ITR-6 online 18 Aug 2026, offline 20 Aug 2026, extension 29 Sep 2026), read 2 Oct 2026, https://www.incometax.gov.in/iec/foportal/latest-news
• CBDT, Circular No. 07/2026, F. No. 225/128/2026/ITA-II, 28 Sep 2026, https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-09/Circular-7-2026.pdf
• Income Tax Department, Income Tax Returns help page (new forms for tax year 2026-27), read 2 Oct 2026, https://www.incometax.gov.in/iec/foportal/help/all-topics/e-filing-services/income-tax-returns
• Income Tax Department, Register Digital Signature Certificate FAQ, read 2 Oct 2026, https://www.incometax.gov.in/iec/foportal/help/how-to-register-e-filing-dsc-faq
• Income Tax Department, Instructions to Form ITR-6 (AY 2021-22, verification by digital signature only), read 2 Oct 2026, https://www.incometax.gov.in/iec/foportal/sites/default/files/2021-05/Instructions_ITR6_AY2021_22.pdf
• Income Tax Department, Section 139 of the Income Tax Act, 1961 (as amended by Act No. 4 of 2026), read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-139-93
• Income Tax Department, Section 234-I of the Income Tax Act, 1961, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-234i
• Income Tax Department, Section 234F of the Income Tax Act, 1961, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-234f-10
• Income Tax Department, Return of income (verification, late filing, losses), read 2 Oct 2026, https://www.incometaxindia.gov.in/w/return-of-income-2
• Income Tax Department, Section 263 of the Income Tax Act, 2025, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-263-72
• Income Tax Department, Section 428 of the Income Tax Act, 2025, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-428-6
• Income Tax Department, Section 265 of the Income Tax Act, 2025 (Return by whom to be verified), read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-265-72
• Income Tax Department, Section 200 of the Income Tax Act, 2025, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-200-75
• Income Tax Department, Section 115BAA of the Income Tax Act, 1961, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-115baa-2
• Income Tax Department, Tax rates for AY 2026-27, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/tax-rates%E2%80%8B
• Income Tax Department, Special regimes for taxation of companies (section 115BAA, Form 10-IC), read 2 Oct 2026, https://www.incometaxindia.gov.in/w/special-regimes-for-taxation-of-individuals-huf-aop-boi-ajp-companies-and-co-operative-societies
• Income Tax Department, Minimum Alternate Tax and Alternate Minimum Tax, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/%E2%80%8Bminimum-alternate-tax-and-alternate-minimum-tax%E2%80%8B
• Income Tax Department, MAT and AMT under the Income Tax Act, 2025, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/mat-and-amt
• Income Tax Department, Schedule SH-1: Shareholding of Unlisted Company, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/schedule_sh-1
• Income Tax Department, Section 43 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/section-43-114
• Income Tax Department, FAQs on Budget 2026 (revised and updated returns, MAT), read 2 Oct 2026, https://www.incometaxindia.gov.in/documents/20117/15766092/FAQs-Budget-2026.pdf/ff3d0e10-88a0-b11f-3c27-b58375974227
• CBDT, Updated FAQs on Interplay and Transitions (Q3.4 to Q3.12, Q3.21, Q4.39), read 2 Oct 2026, https://www.incometaxindia.gov.in/documents/81799/11848482/Updated-FQAs-on-Interplay&Transitions.pdf/e10ad2b6-9495-de90-58d3-20606d8954ae?t=1775128640970
• Income Tax Department, FAQs and Guidance Notes on Forms as per Income Tax Rules, 2026 (old to new form map), read 2 Oct 2026, https://www.incometaxindia.gov.in/faqs-and-guidance-notes-on-forms-as-per-income-tax-rules-2026