ODI Rules 2022 for Indian Companies Investing Abroad in 2026

Written by Nihal Srivastava, Krystal7 Consultants. Last updated 2 October 2026.

The ODI rules are the Foreign Exchange Management (Overseas Investment) Rules, 2022 and the Overseas Investment Regulations, 2022, both in force since 22 Aug 2022. An Indian company may invest abroad on the automatic route up to 400 percent of its net worth, as per its last audited balance sheet. It must report in Form FC through one designated AD bank before the first remittance, which gives it a UIN. Commitments above USD 1 billion in a financial year need RBI approval.

This guide covers the 2022 framework as it stands on 2 Oct 2026. It explains the limits, the forms, the two layer round tripping rule, annual reporting, late fees and exits, with worked figures.

What are the ODI rules 2022?

The ODI rules are three instruments read together. The Central Government's Overseas Investment Rules, 2022 set the policy and limits. RBI's Overseas Investment Regulations, 2022 set debt, guarantees, reporting and late fees. RBI's Master Direction on Overseas Investment tells AD banks how to run it all.

The Ministry of Finance notified the Foreign Exchange Management (Overseas Investment) Rules, 2022 as G.S.R. 646(E) on 22 Aug 2022. We call them the OI Rules.

The same day, RBI notified the Foreign Exchange Management (Overseas Investment) Regulations, 2022 as Notification No. FEMA 400/2022-RB. We call them the OI Regulations.

RBI also issued the Overseas Investment Directions, 2022 as A.P. (DIR Series) Circular No. 12 of 22 Aug 2022. Those Directions now sit in the Master Direction on Overseas Investment, FED Master Direction No. 15/2024-25 of 24 Jul 2024. The current text is updated as on 1 Apr 2026. We call it the Master Direction below.

The PIB release of 22 Aug 2022 said many transactions that once needed approval moved to the automatic route. The 2022 framework replaced the old ODI regulations, FEMA 120/2004-RB, and the 2015 regulations on immovable property outside India.

Instrument	Issued by	Number and date	What it covers
OI Rules	Central Government	G.S.R. 646(E), 22 Aug 2022	Definitions, who may invest, limits (Schedules I to V), pricing, transfer, restructuring, prohibitions, the two layer rule
OI Regulations	RBI	FEMA 400/2022-RB, 22 Aug 2022	Debt, guarantees, pledges, deferred payment, mode of payment, obligations, reporting, late fees
Master Direction	RBI	FED Master Direction No. 15/2024-25, 24 Jul 2024, updated as on 1 Apr 2026	Operating instructions for AD banks, the late fee table, Regional Office mapping
Form FC and Form APR	RBI	Issued with the 2022 framework	The reporting forms filed through the AD bank

The OI Rules have 21 rules and five Schedules. Rule 9 holds the core permission. Rule 11 routes ODI by an Indian entity to Schedule I. Rule 19 holds the prohibitions and the two layer rule.

Rule of the OI Rules	Heading
2	Definitions
4	Non applicability in certain cases
9	Overseas investment (bona fide business activity)
10	No Objection Certificate
11	Manner of making ODI by an Indian entity (Schedule I)
12	Manner of making OPI by an Indian entity (Schedule II)
13	Overseas investment by a resident individual (Schedule III)
15	Overseas investment in IFSC
16	Pricing guidelines
17	Transfer or liquidation
18	Restructuring
19	Restrictions and prohibitions
21	Restriction on acquisition or transfer of immovable property outside India

What is ODI and how is it different from OPI?

ODI, or overseas direct investment, is any purchase of unlisted equity of a foreign entity. It also covers 10 percent or more of a listed foreign entity, or a smaller listed stake with control. OPI, or overseas portfolio investment, is any other investment in foreign securities. A listed stake below 10 percent without control is OPI.

Paragraph 1 of the Master Direction restates the OI Rules definition. ODI means "acquisition of any unlisted equity capital or subscription as a part of the Memorandum of Association of a foreign entity". It also covers 10 percent or more of the paid up equity of a listed foreign entity. And it covers a smaller listed stake that comes with control.

Control means "the right to appoint majority of the directors or to control the management or policy decisions". It includes rights under shareholders' or voting agreements "that entitle them to ten percent or more of voting rights". So 10 percent of the votes counts as control.

Two practical points follow. Any unlisted foreign share is ODI, however small the stake. And once an investment counts as ODI, it stays ODI even if the stake later drops.

A foreign entity must also have limited liability. Rule 2 defines it as an entity formed, registered or incorporated outside India "that has limited liability". The proviso lifts the limited liability test where the core activity is in a strategic sector. Strategic sectors are energy and natural resources such as oil, gas, coal, mineral ores, submarine cable systems, and start ups.

Point	ODI	OPI
What it is	Unlisted foreign equity; 10% or more of a listed foreign entity; or any listed stake with control	Other foreign securities, such as a listed stake below 10% without control
Indian company that may make it	Any Indian entity eligible under Schedule I	A listed Indian company; an unlisted Indian entity only in limited cases
Limit for an Indian entity	Total financial commitment up to 400% of net worth	Up to 50% of net worth (Schedule II)
First report	Form FC before the first remittance, to get a UIN	Form OPI, half yearly
Annual report	Form APR by 31 December	No APR
Debt and guarantees allowed	Yes, once ODI with control exists	No

Schedule II to the OI Rules caps an Indian entity's OPI at 50 percent of its net worth. Net worth comes from the last audited balance sheet. A listed Indian company may make OPI, including by reinvestment. An unlisted Indian entity may make OPI only in narrow cases, such as rights and bonus shares, capitalisation and a swap of securities. For the inbound version of the same split, see our note on FDI vs FPI in India.

Who can make ODI under the automatic route?

An Indian entity can make ODI under the automatic route if the foreign entity runs a bona fide business and no prohibition applies. Indian entity means a company, a body corporate, an LLP or a registered partnership firm. It must stay within the 400 percent limit. It must also report through one designated AD bank.

Rule 9 is the gateway. Any overseas investment "shall be made in a foreign entity engaged in a bona fide business activity". The Explanation to rule 9(1) defines the term. It means "any business activity permissible under any law in force in India and the host country". Paragraph 3 of the Master Direction adds that the investment may be made directly or through a step down subsidiary or a special purpose vehicle.

Rule 2 lists four kinds of Indian entity. They are a company under the Companies Act, 2013, a body corporate set up by any law, an LLP, and a registered partnership firm. A foreign owned Indian company is an Indian entity too. It invests abroad on the same terms as an Indian owned company.

Approval is needed only in defined cases. The table sets them out.

Situation	Route	Where it is set out
ODI by an Indian entity within 400% of net worth, in a permitted activity	Automatic, through the AD bank	Rule 11 and Schedule I, OI Rules
Financial commitment above USD 1 billion in one financial year	Prior RBI approval, even within the 400% limit	Master Direction paragraph 5
Financial commitment above 400% of net worth	Outside the automatic route; RBI may permit it on an application through the designated AD bank	Schedule I paragraph 3; rule 9(2)(ii)
Commitment above the limits in a strategic sector or geography	The Central Government may permit it on an application made through RBI	Rule 9(2)(i)
Investment in Pakistan or any jurisdiction the Central Government advises	Central Government approval, sent through the AD bank and RBI	Master Direction paragraph 4
Investor whose account is an NPA, who is a wilful defaulter, or who is under investigation	NOC from the lender, regulator or agency first	Rule 10; Master Direction paragraph 6
Foreign entity dealing in financial products linked to the rupee	Specific RBI approval	Rule 19(1)(c)
Real estate activity or gambling	Not permitted	Rule 19(1)(a) and (b)

Where RBI approval is needed, the applicant approaches its designated AD bank. The bank scrutinises the proposal and forwards it to the RBI Regional Office. It uses the PRAVAAH portal. Paragraph 3(3) of the Master Direction sets this out.

That routing came in with A.P. (DIR Series) Circular No. 02 of 1 Apr 2026. Paragraph 26(3) of the Master Direction maps the Regional Office to the UIN prefix. For example, ND goes to New Delhi and BG to Bengaluru.

Resident individuals have their own Schedule III. They may make ODI only in an operating foreign entity not engaged in financial services. That entity must not have a subsidiary or step down subsidiary where the individual has control. The money counts against the Liberalised Remittance Scheme limit.

How much can an Indian company invest abroad?

An Indian company may make a total financial commitment of up to 400 percent of its net worth in all foreign entities taken together. Net worth is taken from the last audited balance sheet. Equity, loans and guarantees all count. Separately, anything above USD 1 billion in a single financial year needs prior RBI approval.

What counts as financial commitment

The OI Rules define financial commitment as a total of three things. They are ODI, debt other than OPI, and non fund based facilities given for foreign entities. So the limit is one bucket for every foreign entity. It is not a separate 400 percent for each subsidiary.

The OI Rules adopt the meaning of net worth in section 2(57) of the Companies Act, 2013. That is paid up capital plus reserves created out of profits and securities premium, less accumulated losses and deferred expenditure not written off. Revaluation reserves, write back of depreciation and amalgamation reserves stay out.

Paragraph 3 of Schedule I takes net worth "as on the date of the last audited balance sheet". Paragraph 21(8) of the Master Direction points back to that paragraph for the limit. Paragraph 21(4) adds that an Indian entity may no longer use the net worth of its subsidiary or holding company to raise the limit.

How each type of commitment is counted

Type of financial commitment	Amount counted towards the 400% limit	Source
Equity (ODI)	Full amount invested	Schedule I, OI Rules
Loan or debt instrument to the foreign entity	Full amount	Regulation 4, OI Regulations
Corporate guarantee	Full amount of the guarantee; the 50% treatment is for performance guarantees only	Regulations 3(2) and 5, OI Regulations
Performance guarantee	50% of the amount	Regulation 5(6), OI Regulations
Guarantee given jointly and severally by two or more Indian entities	100% of the amount against each entity's own limit	Regulation 5(5), OI Regulations
Personal guarantee by a resident individual promoter	Counts against the Indian entity's limit	Regulation 5(2), OI Regulations
Pledge or charge on assets for a foreign entity's facility	Value of the pledge or charge, or the amount of the facility, whichever is less	Regulation 6; Master Direction paragraph 21(5)
Guarantee by a 51% holding or subsidiary company in India	Counts against that group company's own limit	Regulation 5(2); Master Direction paragraph 21(4)(e)
Roll over of a guarantee	Not a fresh commitment where the rolled over amount does not exceed the original guarantee; still reported in Form FC	Regulation 5(7); Master Direction paragraph 21(4)(d)
Deferred part of the purchase price	Non fund based commitment until paid	Regulation 7; Master Direction paragraph 10

What happens above the 400 percent ceiling? Paragraph 3 of Schedule I says the total commitment "shall not exceed" 400 percent of net worth. The only other figure it allows is one "as directed by the Reserve Bank, in consultation with Central Government". Neither the OI Rules nor the OI Regulations give an automatic path above the limit. So a commitment above it is outside the automatic route.

Rule 9(2) holds the two ways to ask. Under rule 9(2)(i), the Central Government may permit a commitment "in strategic sectors or geographies, above the limits laid down in these rules". That application goes through RBI. Under rule 9(2)(ii), RBI may permit an investment or commitment "for sufficient reasons", on an application through the designated AD bank. So the company should approach RBI through its AD bank before it commits. The permission is discretionary, and no rule promises it.

Debt and guarantees need ODI with control first

Regulation 3 of the OI Regulations sets three conditions for any commitment other than equity. The Indian entity must be eligible to make ODI. It must already have made ODI in the foreign entity. And it must have "acquired control in such foreign entity at the time of making such financial commitment".

Loans must be "duly backed by loan agreement" with interest charged on an arm's length basis (regulation 4). An Indian entity "shall not lend directly to its overseas SDS" (Master Direction paragraph 21(3)). It lends to the first level entity, which lends on.

Guarantees can come from four givers under regulation 5:

1. The Indian entity itself, as a corporate or performance guarantee.
2. A group company in India. It may be a holding company with at least 51 percent of the Indian entity, or a subsidiary at least 51 percent owned by it. A promoter group company that is a body corporate also qualifies.
3. A resident individual promoter, as a personal guarantee.
4. An Indian bank, backed by a counter guarantee or collateral from the Indian entity.

Regulation 5 bars open ended guarantees, so each must state an amount and a period. To the extent a guarantee is invoked, it stops being non fund based and is treated as lending.

Financial services and start ups

Schedule I sets extra conditions for financial services. An Indian entity in financial services needs net profits in the preceding three financial years to invest in foreign financial services. It must also be registered with or regulated by a financial services regulator in India, and get the regulators' approvals. An Indian entity outside financial services may also invest in foreign financial services, other than banking or insurance. It too needs net profits in the preceding three financial years.

Two relaxations apply. Paragraph 21(7) of the Master Direction covers an entity that misses the three year profit test. It may still make such ODI in a foreign entity in an IFSC in India. And the proviso in Schedule I lets an Indian entity outside the insurance sector invest in general and health insurance abroad. That insurance business must support the core activity the Indian entity runs overseas.

ODI in a start up abroad has a funding rule. Rule 19(2) says it must come "only from the internal accruals" of the Indian entity or its group or associate companies in India. Paragraph 9 of the Master Direction says it "shall not be made out of funds borrowed from others".

Which forms are filed for ODI?

The main form is Form FC. You file it with your designated AD bank "on or before making initial ODI". The bank reports it to RBI to get a Unique Identification Number (UIN). Every later commitment, restructuring and exit goes in Form FC too. Form APR follows each year, plus the FLA return.

Form FC does the work of Form ODI Part I

Under the old FEMA 120/2004-RB regime, banks reported ODI in Form ODI. Part I covered the first investment and later remittances. Part II was the annual performance report. Part III covered disinvestment. Under the 2022 framework, commitments, restructuring and disinvestment are reported under regulation 10 in Form FC. The annual report is Form APR.

RBI's text does not use the word "replaced". The late fee table in paragraph 18 of the Master Direction lists the old and new names side by side. One row pairs Form ODI Part II with Form APR. The other groups Form ODI Part I, Form ODI Part III and Form FC. So when a bank asks for "ODI Part I" on a new investment, it means Form FC.

Form FC has seven sections:

Section of Form FC	Content	Who completes it
A	Details of the Indian entity or resident individual	Investor
B	Details of the foreign entity and step down subsidiaries	Investor
C	Details of the transaction, remittance or financial commitment	Investor
D	Declaration by the Indian entity or resident individual, including NPA, wilful defaulter and investigation status	Investor
E	Certificate by the statutory auditors of the Indian entity or group company	Statutory auditor
F	Restructuring of the foreign entity's balance sheet	Investor and auditor
G	Disinvestment in the foreign entity	Investor

The Form FC instructions say the form is filed "at the time of sending outward remittance or making a financial commitment, whichever is earlier". It applies on both the automatic and the approval route.

The UIN

Regulation 9(2) requires the investor to obtain a UIN "before sending outward remittance or acquisition of equity capital", whichever is earlier. Paragraph 16 of the Master Direction warns that "the allotment of UIN does not constitute an approval from the Reserve Bank". It only records the investment. The bank still checks the bona fides, KYC and FEMA compliance under paragraph 27.

For later commitments, paragraph 27(1) gives the AD bank 15 more days to report to RBI. That time belongs to the bank, so your own deadline does not move.

One designated AD bank

Paragraph 26 of the Master Direction requires all transactions for one foreign entity to go through one designated AD bank. To change banks, you need a no objection certificate from the existing bank.

The full reporting map

Event	Form or step	Due	Legal basis
First investment in a foreign entity	Form FC, UIN allotted	Before the first remittance or commitment, whichever is earlier	Regulation 9(2) and 10(2); Master Direction paragraph 16
Each later equity, loan, guarantee or pledge	Form FC	At remittance or commitment, whichever is earlier	Regulation 10(2)
Roll over of a guarantee	Form FC	At roll over	Master Direction paragraph 21(4)(d)
Evidence of investment (share certificate)	Submit to AD bank	Within six months of remittance or capitalisation	Regulation 9(1)
Dues from the foreign entity (dividend, interest, fees)	Repatriate to India	Within 90 days of falling due	Regulation 9(4)
Restructuring of the foreign entity's balance sheet	Form FC, Section F	Within 30 days of the restructuring	Regulation 10(2)
Disinvestment, transfer or liquidation	Form FC, Section G	Within 30 days of receiving the proceeds	Regulation 10(2)
OPI by an Indian entity (not resident individuals)	Form OPI	Within 60 days of the end of each half year ending September and March	Regulation 10(3)
Annual performance	Form APR	By 31 December each year	Regulation 10(4)
Foreign liabilities and assets	FLA return on FLAIR	15 July each year	Regulation 10(5); RBI FLA FAQ

Paragraph 8 of the Master Direction covers bids and tenders. The bank may remit an earnest money deposit after Form A2, or issue a bid bond guarantee. Form FC follows once you win.

What is the round tripping restriction?

Rule 19(3) of the OI Rules targets foreign entities that have invested, or later invest, into India. You may not commit money to one if the result is "a structure with more than two layers of subsidiaries". So an Indian company may own a foreign company that owns an Indian company. It may not add a third layer of subsidiaries in such a loop.

The rule applies to investment into India made "at the time of making such financial commitment or at any time thereafter". It also covers investment made "either directly or indirectly".

Three features matter in practice.

1. It is a continuing test. The words "at any time thereafter" mean a later Indian investment by the foreign entity can breach the rule.
2. It counts indirect investment. A step down subsidiary that invests in India counts.
3. Old structures are frozen. Paragraph 20(2) of the Master Direction deals with structures already in place when the OI Rules were notified. Where one has two or more layers, no further layer of subsidiaries may be added.

The proviso exempts four classes of company. They are the classes listed in rule 2(2) of the Companies (Restriction on Number of Layers) Rules, 2017. Three are banking companies, insurance companies and Government companies. The fourth is a non banking financial company registered with RBI that RBI treats as systemically important. Any other NBFC gets no exemption.

Neither the OI Rules nor the Master Direction defines "layer". Our reading counts each level of subsidiary below the Indian investor. A subsidiary here means an entity in which the foreign entity has control, which can be as little as 10 percent of the votes. The table applies that reading.

Structure	Layers of subsidiaries (our reading)	Permitted under rule 19(3)?
IndCo owns US Inc; US Inc makes no investment in India	1	Yes; rule 19(3) is not triggered
IndCo owns US Inc; US Inc owns India Private Limited	2	Yes
IndCo owns US Inc; US Inc owns Singapore Pte; Singapore Pte owns India Private Limited	3	No
IndCo owns UK Ltd and UK Ltd owns a German GmbH; no Indian investment anywhere	2	Yes; rule 19(3) is not triggered
A banking company or a systemically important NBFC with a three layer structure into India	3	Yes; the proviso exempts it

Part X of Form APR asks for any investment into India by the foreign entity or its step down subsidiaries. That is where the AD bank and RBI see the loop. Our APR guide covers that part.

The two layer rule sits beside section 186(1) of the Companies Act, 2013. It allows investment "through not more than two layers of investment companies". Section 186(1) counts investment companies, while rule 19(3) counts subsidiaries. The first proviso to section 186(1) covers the purchase of a foreign company. Its investment subsidiaries may go beyond two layers if that country's law allows. Rule 19(3) has no such exception. So check both tests.

Round tripping also has an inbound FEMA side. An Indian investment by the foreign subsidiary is still inbound FDI. The Indian company it buys files FC-GPR or FC-TRS under the inbound rules. Our guide on share transfer to a non resident in Form FC-TRS covers that end.

Which activities and countries are prohibited?

Rule 19(1) bars ODI in a foreign entity engaged in real estate activity or gambling in any form. It also bars dealing in financial products linked to the Indian rupee without specific RBI approval. Investment in Pakistan, or any jurisdiction the Central Government advises, needs Central Government approval.

The Explanation to rule 19(1) narrows "real estate activity". It means "buying and selling of real estate or trading in Transferable Development Rights". It does not include building townships, residential or commercial premises, roads or bridges for sale or lease. So a foreign construction company is allowed. A foreign company that trades land is not.

Paragraph 20(1) of the Master Direction tells AD banks not to facilitate any transaction for a foreign entity engaged in a rule 19(1) activity. Rupee linked products include non deliverable forwards and rupee linked derivatives.

Activity of the foreign entity	Position under the OI Rules
Software, consulting, trading, manufacturing	Permitted on the automatic route if bona fide
Construction of buildings, roads or bridges for sale or lease	Permitted; outside the real estate definition
Buying and selling land or trading development rights	Prohibited
Gambling in any form	Prohibited
Financial products linked to the Indian rupee	Only with specific RBI approval
Financial services (other than banking and insurance) by a non financial Indian entity	Permitted after three years of net profits
Start up abroad	Permitted from internal accruals only
Any entity in Pakistan or an advised jurisdiction	Central Government approval

What does an Indian company need under the Companies Act?

The Companies Act decides who inside the company may approve the investment. Section 186(5) requires a board resolution passed with the consent of all directors present. Section 186(3) requires a special resolution above the section 186(2) limit. Its proviso lifts that for a wholly owned subsidiary, and for loans or guarantees to a joint venture.

Section 186(2) limits loans, guarantees, security and acquisitions of securities to the higher of two figures. One is 60 percent of paid up share capital, free reserves and securities premium. The other is 100 percent of free reserves and securities premium.

The proviso to section 186(3) lifts the special resolution for a wholly owned subsidiary. It covers buying its securities, and loans, guarantees or security given to it or to a joint venture. Buying shares in a joint venture stays inside the special resolution rule. A second proviso requires the company to disclose these transactions in its financial statements under section 186(4).

The unanimous board consent in section 186(5) still applies. Section 186(5) also needs the prior approval of a public financial institution where a term loan from it is outstanding. Its proviso drops that approval where the total stays within the section 186(2) limit and the loan is not in default.

Test	FEMA (OI Rules)	Companies Act, 2013
Base	Net worth under section 2(57), last audited balance sheet	Paid up capital, free reserves and securities premium
Limit	400% of net worth for all foreign commitments	Higher of 60% of the base or 100% of free reserves and premium, for all loans and investments
Above the limit	Outside the automatic route; apply to RBI through the AD bank under rule 9(2)	Special resolution (not needed for a wholly owned subsidiary)
Layers	No more than two layers of subsidiaries where the structure invests back into India	Investment through no more than two layers of investment companies
Approval inside the company	Board resolution for Form FC	Board resolution with consent of all directors present

Can an Indian company set up a US subsidiary under the automatic route?

Yes. A Delaware corporation or a US LLC has limited liability, so it is a foreign entity under the OI Rules. If it runs a bona fide business and the total commitment stays within 400 percent of net worth, no RBI approval is needed. You file Form FC, get a UIN and remit through the designated AD bank.

Most Indian founders we work with choose a Delaware C corporation for investors, or an LLC for a simple sales arm. Both fit the limited liability test. A US general partnership does not, unless its core activity is in a strategic sector.

The sequence we follow for a US subsidiary runs like this:

1. Confirm the US business is bona fide and outside rule 19(1).
2. Work out net worth from the last audited balance sheet and test the 400 percent limit.
3. Pass the board resolution under section 186(5), and a special resolution if section 186(3) applies.
4. Incorporate the US company and get its formation documents.
5. Fill Form FC, Sections A to E, with the statutory auditor's certificate.
6. Submit Form FC to the designated AD bank and get the UIN.
7. Remit the share subscription, or capitalise dues, through that bank.
8. Get the share certificate and hand it to the bank within six months.
9. File the FLA return by 15 July and Form APR by 31 December each year.

The US company itself has US filings. A US subsidiary that pays dividends to its Indian parent withholds US tax. The India US treaty caps that at 15 percent for a company holding at least 10 percent of the voting stock, and 25 percent otherwise. Our India US DTAA guide covers the treaty.

If the US subsidiary later sets up an Indian company, the structure has two layers. That is allowed. If it does so through a further US or Singapore holding company, it has three layers and breaches rule 19(3).

How is ODI priced, and can payment be deferred?

Rule 16 of the OI Rules requires transfers and issues to be at an arm's length price, "after taking into consideration the valuation as per any internationally accepted pricing methodology". Paragraph 12 of the Master Direction leaves the documents to each AD bank's board approved policy. Payment may be deferred for a defined period under regulation 7.

Paragraph 12 lists cases where the bank need not insist on a valuation. They include a merger, demerger or liquidation priced by a court or tribunal, and a price readily available on a recognised stock exchange. For a fresh subscription in a new wholly owned subsidiary at face value, banks usually follow their own policy on whether to ask for a valuation. Our valuation reports page lists what we prepare for ODI.

Regulation 7 allows part of the price to be deferred "for definite period". The foreign securities must be transferred upfront. The deferred part counts as a non fund based commitment, so it uses the 400 percent limit. Paragraph 10 of the Master Direction says later payments go in Form FC as conversion of that commitment to equity. The whole price must meet the pricing rules, valued upfront.

What annual reporting applies?

Two annual returns apply to every Indian company with ODI. Form APR goes to the designated AD bank by 31 December for each foreign entity, on audited accounts. The FLA return goes to RBI on the FLAIR portal by 15 July. A listed Indian company with OPI also files Form OPI every half year.

Regulation 10(4) makes Form APR due "every year by 31st December". Where the foreign entity's year ends on 31 December, the APR is due by 31 December of the next year. The proviso exempts a holding below 10 percent without control where equity is the only commitment. It also exempts an entity under liquidation.

The APR needs audited accounts unless the Indian investor has no control and host law requires no audit. So a wholly owned subsidiary needs an audit even where its own country exempts it. Our full Annual Performance Report guide walks through all twelve parts of Form APR.

Return	Due	Filed with	Accounts basis	Late fee
Form APR	31 December (31 December of the next year for a 31 December year end)	Designated AD bank	Audited, with narrow exceptions	INR 7,500 flat
FLA return	15 July	RBI, on FLAIR	Provisional allowed, revise later	INR 7,500 flat
Form OPI	60 days after each half year ending September and March	Designated AD bank	Not applicable	INR 7,500 flat
Evidence of investment	Six months from remittance	Designated AD bank	Not applicable	INR 7,500 flat

What happens if ODI reporting is late?

A late report can be filed within three years of its due date with a late submission fee (LSF) under regulation 11. Form FC pays INR 7,500 plus 0.025 percent of the amount for each year of delay. APR, FLA and Form OPI pay a flat INR 7,500. Until you regularise, regulation 12 blocks any further commitment or transfer.

Paragraph 18 of the Master Direction sets the formula as INR 7,500 + (0.025% × A × n). "A" is the amount involved. "n" is the years of delay, rounded up to the nearest month and expressed to two decimals. The fee is capped at 100 percent of A and rounded upwards to the nearest hundred.

Type of reporting (Master Direction paragraph 18)	Forms	LSF in INR
Periodic reporting that does not capture flows	Form ODI Part II or APR, FLA return, Form OPI, evidence of investment	7,500
Reporting that captures flows or non fund based commitments	Form ODI Part I, Form ODI Part III, Form FC	7,500 + (0.025% × A × n)
Cap	All	100% of A, rounded up to the nearest hundred

The LSF is paid by demand draft in favour of "Reserve Bank of India", payable at the Regional Office for your UIN prefix. If RBI issues an advice and you do not pay within 30 days, the advice lapses.

The three year window

Regulation 11(1) keeps the LSF route open for three years from the due date. Regulation 11(2) gave delays under the old FEMA 120/2004-RB regime three years from 22 Aug 2022. That window closed in August 2025. So a delay from the old regime now needs compounding.

Regulation 12 is the real cost

Regulation 12 says a person with a reporting delay "shall not make any further financial commitment" in that foreign entity, directly or indirectly. It also bars any transfer of the investment. This lasts "till delay in reporting is regularised". A pending capital call, a new loan or a sale of the stake waits until the report is in and the fee is paid.

After three years

A delay older than three years, or any other FEMA contravention, goes to compounding under the Foreign Exchange (Compounding Proceedings) Rules, 2024. RBI's compounding FAQ sets an application fee of INR 10,000 plus GST. The application can go through PRAVAAH, and the compounded amount is due within 15 days of the order.

Without compounding, section 13(1) of the Foreign Exchange Management Act, 1999 applies. It allows a penalty of up to three times the sum involved, where that sum is quantifiable. Our FEMA compounding application guide walks through the file. For an overseas file with several gaps, our compliance rescue team maps every UIN first.

How do disinvestment, liquidation and restructuring work?

Rule 17 of the OI Rules lets an Indian entity sell, transfer or liquidate its ODI on the automatic route. In a full disinvestment other than by liquidation, the seller must have no dues outstanding from the foreign entity. It must also have stayed invested for at least one year from the date of the ODI. You report the exit in Form FC, Section G, within 30 days of receiving the proceeds.

Rule 17 has these main conditions:

1. The transferor "shall not have any dues outstanding" in a full disinvestment other than by liquidation.
2. The transferor "must have stayed invested for at least one year from the date of making ODI". This applies to any disinvestment, full or partial.
3. Neither condition applies to a merger, demerger or amalgamation between foreign entities that the Indian entity wholly owns, directly or indirectly. The same holds where the Indian entity's total equity holding does not change or dilute.
4. The price must meet rule 16.
5. A transfer by merger, amalgamation, demerger or buyback, and a liquidation, needs the approval of the competent authority. Indian law or the host country's law decides who that is.

Paragraph 13 of the Master Direction narrows the dues test. Dues that do not arise from the equity or debt investment, such as export receivables, need not be repatriated before the exit. If the investor's account is an NPA, or it is a wilful defaulter or under investigation, it needs an NOC before disinvesting (paragraph 6).

Regulation 9(4) then requires the sale or liquidation proceeds to come back to India within 90 days.

Restructuring a loss making entity

Rule 18 allows a restructuring of the foreign entity's balance sheet that reduces the Indian investor's dues. The foreign entity must have made losses in each of the previous two years, on its last audited balance sheet. The diminution may not exceed the proportionate share of accumulated losses.

Two cases need a valuer to certify the diminution at arm's length. One is an original investment above USD 10 million. The other is a diminution above 20 percent of the total outstanding dues. The certifier may be a registered valuer under the Companies Act, 2013. It may also be a registered valuer or certified public accountant in the host jurisdiction. The certificate must be dated within six months before the transaction and goes to the designated AD bank.

Rule 18 measures the diminution on dues from both equity and debt. Paragraph 14 of the Master Direction has the AD bank obtain a certificate on the accumulated losses and the proportionate share. You report the restructuring in Form FC, Section F, within 30 days.

How does income tax apply to ODI after 1 April 2026?

The Income Tax Act, 2025 applies from 1 Apr 2026, and the forms changed numbers. ODI remittances under purpose codes S0001 to S0005, and loans to non residents under S0011, need no Form 145 (old Form 15CA). Transactions with the foreign subsidiary need the transfer pricing report in Form 48 (old Form 3CEB).

Rule 220 of the Income Tax Rules, 2026 lists 33 payments that need no Form 145. The list includes code S0003, Indian investment abroad in branches and wholly owned subsidiaries. It also includes code S0011, loans extended to non residents. Rule 220(3) applies where the sum is not chargeable to tax in India. So a share subscription or loan to a foreign subsidiary under these codes needs no Form 145. With no Form 145, no Form 146 certificate arises. Fees or interest you pay to the subsidiary are different and may need both. Our Form 15CA and 15CB guide covers those cases.

A loan, guarantee, cost recharge or service fee with the foreign subsidiary is an international transaction. It needs an arm's length price and the accountant's report under section 172 of the Income Tax Act, 2025, in Form 48. Dividend or interest from the subsidiary is taxed in India. Credit for foreign tax is claimed in Form 44 (old Form 67). Our guide to foreign tax credit and Form 67 covers the claim.

Item	Under the Income Tax Act, 1961	Under the Income Tax Act, 2025 (from 1 Apr 2026)
Information on a remittance to a non resident	Form 15CA, rule 37BB	Form 145, rule 220
Accountant's certificate on a remittance	Form 15CB	Form 146, rule 220
ODI and loan remittances exempt from the forms	Rule 37BB specified list	Rule 220(3)(c) list, codes S0001 to S0005 and S0011
Transfer pricing report	Form 3CEB, section 92E	Form 48, section 172
Foreign income and foreign tax credit statement	Form 67	Form 44
Treaty relief	Section 90	Section 159
Withholding on payments to non residents	Section 195	Section 393

What changed in 2026

We found no 2025 or 2026 amendment to the OI Rules limits, the OI Regulations or the forms. RBI's FEMA notifications page lists FEMA 400/2022-RB with no amendment as on 2 Oct 2026. The changes that touch an ODI file are about RBI routing, guarantees outside the OI framework, closing late fee windows and income tax form numbers.

Date	Earlier position	Position now	Instrument	Effect on ODI
22 Aug 2022	FEMA 120/2004-RB; Form ODI Parts I to III	OI Rules, OI Regulations; Form FC and Form APR	G.S.R. 646(E); FEMA 400/2022-RB; A.P. (DIR Series) Circular No. 12	Base framework, still in force
24 Jul 2024	Directions issued as a circular	Directions carried in the Master Direction	FED Master Direction No. 15/2024-25	No change in substance
August 2025	LSF available for old regime delays	Three year window from 22 Aug 2022 closed	Regulation 11(2)	Old regime delays need compounding
28 Nov 2025	Master Direction referred to the old KYC Master Direction	Reference removed	A.P. (DIR Series) Circular No. 16	None in substance
6 Jan 2026	Guarantees Regulations, 2000	Guarantees Regulations, 2026 with Form GRN from 1 Apr 2026	FEMA 8(R)/2026-RB	None; regulation 4(c) excludes guarantees under the OI Regulations, which stay in Form FC
1 Apr 2026	Approval and other references handled at RBI Central Office	References and approval applications go to seven Regional Offices by UIN prefix, through PRAVAAH	A.P. (DIR Series) Circular No. 02	Approval route cases and LSF drafts go to the Regional Office
1 Apr 2026	Forms 15CA, 15CB, 3CEB, 67	Forms 145, 146, 48, 44	Income Tax Act, 2025; Income Tax Rules, 2026	ODI remittances under S0001 to S0005 and S0011 still exempt (rule 220)
31 Dec 2026	LSF available for reports due 31 Dec 2023	Window closes	Regulation 11(1)	File any APR due on 31 Dec 2023 before this date

The Guarantees Regulations, 2026 catch many founders out. A parent guarantee for an overseas subsidiary is an ODI commitment. It goes in Form FC, not in the new quarterly Form GRN.

Worked example

IndCo Private Limited is a Gurugram software company with a 31 March year end. It already owns a UAE subsidiary. In October 2026 it plans a new wholly owned Delaware corporation for US sales. The figures below are for illustration.

Net worth from the audited balance sheet at 31 Mar 2026

Item	INR	Counted in section 2(57) net worth?
Paid up share capital	5,00,00,000	Yes
Securities premium	3,00,00,000	Yes
Retained earnings (surplus in profit and loss)	9,00,00,000	Yes
Revaluation reserve on office property	2,00,00,000	No
Preliminary expenses not written off	(50,00,000)	Deducted
Net worth	16,50,00,000

The 400 percent limit and what is already used

Commitment	Face amount in INR	Counted in INR
Limit: 400% of 16,50,00,000		66,00,00,000
UAE subsidiary, equity	10,00,00,000	10,00,00,000
UAE subsidiary, shareholder loan	4,00,00,000	4,00,00,000
Corporate guarantee for the UAE subsidiary's bank facility	8,00,00,000	8,00,00,000
Performance guarantee for a UAE contract (50%)	6,00,00,000	3,00,00,000
Total used		25,00,00,000
Headroom		41,00,00,000

The US subsidiary needs USD 20,00,000 of equity. At an assumed rate of INR 88 to the dollar, that is INR 17,60,00,000. It fits inside the INR 41 crore headroom. It is far below USD 1 billion for the financial year, so no RBI approval is needed. After the remittance, headroom falls to INR 23,40,00,000.

The Companies Act test

The section 186(2) base uses paid up capital, free reserves and securities premium: INR 17,00,00,000. Sixty percent of it is INR 10,20,00,000. One hundred percent of free reserves and premium is INR 12,00,00,000. The limit is the higher figure, INR 12 crore.

IndCo's loans, guarantees and investments already exceed INR 12 crore. But the Delaware company is wholly owned. So the proviso to section 186(3) removes the special resolution for the share subscription. The board still passes the resolution with consent of all directors present under section 186(5).

A late Form FC on the guarantee

Suppose IndCo gave the INR 8 crore corporate guarantee on 10 Feb 2026, but reported it in Form FC only on 25 Sep 2026.

Step	Working	Result
Delay	10 Feb 2026 to 25 Sep 2026 is 7 months and 15 days, rounded up	8 months
n	8 ÷ 12 = 0.6667, to two decimals	0.67
Variable part	0.025% × 8,00,00,000 × 0.67 = 20,000 × 0.67	INR 13,400
Fixed part	Master Direction paragraph 18	INR 7,500
LSF	7,500 + 13,400	INR 20,900
Rounding	Upwards to the nearest hundred	INR 20,900
Cap check	100% of A is INR 8,00,00,000	Cap does not bite

Until IndCo files that Form FC and pays INR 20,900, regulation 12 blocks any new commitment to the UAE subsidiary. The US subsidiary is a separate foreign entity with its own UIN, so regulation 12 does not block it. We still clear the UAE gap first, because the AD bank sees the whole file.

The round tripping check

In 2027, the US company may want an Indian subsidiary to run a support centre. IndCo owns US Inc (layer 1), and US Inc owns the new Indian company (layer 2). That is two layers, so rule 19(3) allows it. If US Inc routed the Indian company through a Singapore holding company, the structure would have three layers and would breach rule 19(3).

Common mistakes

1. Remitting before Form FC. Regulation 9(2) requires the UIN before the first remittance. Fix: file Form FC with the auditor's certificate first, and remit only after the bank confirms the UIN.
2. Testing the 400 percent limit per entity. The limit covers all foreign entities taken together. Fix: keep one register of every UIN with equity, loans and guarantees counted as regulation 5 says.
3. Counting a performance guarantee at full value, or a corporate guarantee at half. Only performance guarantees count at 50 percent. Fix: classify each guarantee by its wording before you compute the limit.
4. Using a group company's net worth. Paragraph 21 of the Master Direction discontinued that. Fix: use only the Indian entity's own net worth from its last audited balance sheet.
5. Lending straight to a step down subsidiary. Paragraph 21(3) of the Master Direction bars it. Fix: lend to the first level entity and let it lend on.
6. Funding a foreign start up with borrowed money. Rule 19(2) requires internal accruals. Fix: fund it from retained cash and keep the bank statement trail.
7. Adding a holding company layer to a structure that invests in India. Rule 19(3) caps it at two layers. Fix: map the whole group, including step down subsidiaries, before any new foreign holding company is set up.
8. Putting an ODI parent guarantee in Form GRN. Regulation 4(c) of the Guarantees Regulations, 2026 excludes it. Fix: report it, and each roll over, in Form FC.
9. Missing the share certificate. Regulation 9(1) gives six months. Fix: ask the foreign company secretary for the certificate the week the money lands.
10. Leaving dividends abroad. Regulation 9(4) gives 90 days from the due date. Fix: track declared dividends, interest and fees in a repatriation register that the auditor can test for Form APR.
11. Selling within a year. Rule 17 requires one year from the date of making ODI. Fix: check that date before you sign a term sheet.
12. Treating Form APR as optional for a dormant entity. Loss or no revenue is not an exemption. Fix: file each year on audited accounts until liquidation starts.

ODI checklist for an Indian company

1. Confirm the foreign business is bona fide and outside rule 19(1).
2. Check that the foreign entity has limited liability, or that its core activity is in a strategic sector.
3. Compute net worth under section 2(57) from the last audited balance sheet.
4. List every existing foreign commitment and count guarantees, pledges and deferred payments as the OI Regulations require.
5. Test the 400 percent limit and the USD 1 billion annual threshold.
6. Check for any NPA, wilful defaulter or investigation status and get an NOC if needed.
7. Map the group for the two layer rule if any part of it invests in India.
8. Pass the board resolution under section 186(5), and a special resolution if section 186(3) applies.
9. Get a valuation where the AD bank's policy or rule 16 requires one.
10. Fill Form FC, Sections A to E, and get the statutory auditor's certificate.
11. Submit Form FC to the designated AD bank and obtain the UIN.
12. Remit through the same bank under purpose code S0001 to S0005, and keep the bank advice.
13. Submit the share certificate to the bank within six months.
14. Report every later loan, guarantee, roll over, restructuring and exit in Form FC on time.
15. Repatriate dues within 90 days, and file the FLA return by 15 July and Form APR by 31 December.

If you want us to run the ODI file end to end, our FEMA compliance team handles Form FC, APR and FLA together.

Frequently Asked Questions

Is Form ODI Part I still used in 2026?+

No. Since 22 Aug 2022, Form FC under regulation 10 of the OI Regulations does the work of Form ODI Part I and Part III. Banks and the late fee table in paragraph 18 of RBI's Master Direction on Overseas Investment still use the old name. A bank request for "ODI Part I" means Form FC with the auditor's certificate.

Does the 400 percent limit apply to each foreign subsidiary separately?+

No. Schedule I to the OI Rules caps the total financial commitment of an Indian entity in all foreign entities taken together at 400 percent of its net worth. Equity, loans, corporate guarantees, half of each performance guarantee and pledges all draw on the same limit. Track every UIN in one register.

Which net worth figure is used for the ODI limit?+

The OI Rules use net worth as defined in section 2(57) of the Companies Act, 2013, taken from the last audited balance sheet. Revaluation reserves, write back of depreciation and amalgamation reserves are excluded. Paragraph 21 of RBI's Master Direction says an Indian entity can no longer use its holding or subsidiary company's net worth.

Can a loss making Indian company make ODI?+

Yes, for most activities. The 400 percent limit runs on net worth, so a company with positive net worth has room even after a loss year. The three year net profit test in Schedule I to the OI Rules applies only to ODI in financial services. A company with negative net worth has no headroom on the automatic route.

Can a foreign owned Indian company invest abroad?+

Yes. A company under the Companies Act, 2013 is an Indian entity under rule 2 of the OI Rules, whoever owns it. It follows the same 400 percent limit, Form FC and APR as an Indian owned company. Watch rule 19(3) closely, since a foreign group often already has investment into India.

Is a US LLC a permitted foreign entity for ODI?+

Yes, in our reading. Rule 2 of the OI Rules requires a foreign entity to have limited liability, unless its core activity is in a strategic sector. A US limited liability company and a Delaware corporation both give their members limited liability. A general partnership does not, so ODI in it needs the strategic sector exception.

Can an Indian company lend to its foreign subsidiary?+

Yes, once it holds ODI with control. Regulation 3 of the OI Regulations needs eligibility, existing ODI and control at the time of the loan. Regulation 4 requires a loan agreement with interest at arm's length. The loan counts toward the 400 percent limit and is reported in Form FC. Direct loans to a step down subsidiary are not allowed.

How is a corporate guarantee for a foreign subsidiary reported?+

Report it in Form FC through the designated AD bank. Regulation 5 of the OI Regulations counts a corporate guarantee at its full amount and a performance guarantee at 50 percent. A guarantee may not be open ended. A roll over is not a fresh commitment if the amount does not rise, but it still goes in Form FC. Form GRN under the Guarantees Regulations, 2026 does not apply.

Do I need Form 15CA for an ODI remittance?+

No, in most cases. Rule 220(3)(c) of the Income Tax Rules, 2026 lists purpose codes S0001 to S0005 for Indian investment abroad and S0011 for loans to non residents. A sum not chargeable to tax under those codes needs neither Form 145 (old Form 15CA) nor Form 146 (old Form 15CB). Fees or interest paid to the subsidiary are outside that list.

Can an Indian company invest in a foreign start up?+

Yes, but only from internal accruals. Rule 19(2) of the OI Rules says ODI in a start up recognised under the host country's laws must come from internal accruals of the Indian entity or its group companies in India. Paragraph 9 of RBI's Master Direction adds that it shall not be made out of funds borrowed from others.

Is ODI in a foreign real estate company allowed?+

Only if it builds rather than trades. Rule 19(1)(a) of the OI Rules bars ODI in real estate activity. The Explanation defines that as buying and selling real estate or trading transferable development rights. Development of townships and construction of residential or commercial premises, roads or bridges for sale or lease is outside the bar.

What is the late fee for a Form FC filed late?+

Paragraph 18 of RBI's Master Direction sets INR 7,500 plus 0.025 percent of the amount times the years of delay. The delay is rounded up to the nearest month and expressed to two decimals. The fee is capped at the amount involved and rounded up to the nearest hundred. The route is open for three years from the due date under regulation 11.

Can I sell my overseas subsidiary within a year of investing?+

Generally no. Rule 17 of the OI Rules requires the transferor to have stayed invested for at least one year from the date of making ODI, with a narrow exception for certain mergers or demergers between wholly owned entities. In a full exit other than liquidation, no dues may be outstanding. Report the sale in Form FC, Section G, within 30 days of receiving the proceeds.

Does a UIN mean RBI has approved my investment?+

No. Paragraph 16 of RBI's Master Direction on Overseas Investment says "the allotment of UIN does not constitute an approval from the Reserve Bank". It only records the investment. The AD bank checks the bona fides, KYC and FEMA compliance under paragraph 27, and a breach found later can still lead to compounding.

Who decides my RBI Regional Office for ODI matters?+

Your UIN prefix decides it. Paragraph 26(3) of RBI's Master Direction maps prefixes to seven Regional Offices, for example ND to New Delhi, BG to Bengaluru and BY to Mumbai. Since A.P. (DIR Series) Circular No. 02 of 1 Apr 2026, the AD bank sends approval applications and references there through PRAVAAH.

Can a resident director hold shares in the Indian company's foreign subsidiary?+

Yes, under Schedule III to the OI Rules, within the Liberalised Remittance Scheme limit. The foreign entity must be an operating entity not engaged in financial services. It must not have a subsidiary or step down subsidiary where the individual has control. A resident individual cannot lend to it, because paragraph 21(3) of the Master Direction bars debt commitments by resident individuals.

Does a missed APR stop dividends from the foreign subsidiary?+

No. Regulation 12 of the OI Regulations bars further financial commitment and transfer until the delay is regularised. It does not bar dividend, interest or fees flowing back. Regulation 9(4) still requires you to repatriate those dues within 90 days. A flat INR 7,500 late fee regularises an APR within three years.

Sources

• Ministry of Finance (Department of Economic Affairs), Foreign Exchange Management (Overseas Investment) Rules, 2022, G.S.R. 646(E), 22 Aug 2022, https://egazette.nic.in/WriteReadData/2022/238239.pdf
• Reserve Bank of India, text of the Foreign Exchange Management (Overseas Investment) Rules, 2022 as hosted on rbi.org.in, read 2 Oct 2026, https://www.rbi.org.in/scripts/bs_viewcontent.aspx?Id=5087
• Reserve Bank of India, Foreign Exchange Management (Overseas Investment) Regulations, 2022, Notification No. FEMA 400/2022-RB, 22 Aug 2022, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12380&Mode=0
• Reserve Bank of India, Foreign Exchange Management (Overseas Investment) Directions, 2022, A.P. (DIR Series) Circular No. 12, 22 Aug 2022, https://rbi.org.in/scripts/NotificationUser.aspx?Mode=0&Id=12381
• Reserve Bank of India, Master Direction on Overseas Investment, FED Master Direction No. 15/2024-25, 24 Jul 2024, updated as on 1 Apr 2026, https://rbi.org.in/scripts/NotificationUser.aspx?Mode=0&Id=12710
• Reserve Bank of India, Form FC with instructions, https://www.rbi.org.in/hindi1/Upload/Returns/PDFs/FORM%20FC7DF68A285653466B9DA18CEBEDCA3263.PDF
• Reserve Bank of India, Overseas Investment, Submission of References to the Reserve Bank, A.P. (DIR Series) Circular No. 02, 1 Apr 2026, https://www.rbi.org.in/scripts/NotificationUser.aspx?Id=13359&Mode=0
• Reserve Bank of India, Foreign Exchange Management (Guarantees) Regulations, 2026, Notification No. FEMA 8(R)/2026-RB, 6 Jan 2026, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13269&Mode=0
• Reserve Bank of India, FEMA notifications list, read 2 Oct 2026, https://www.rbi.org.in/scripts/bs_viewfemanewnotification.aspx
• Reserve Bank of India, FAQs on Compounding of Contraventions under FEMA, 1999, updated 1 Oct 2024, https://www.rbi.org.in/commonman/english/scripts/FAQs.aspx?Id=835
• Ministry of Finance (Press Information Bureau), Overseas investment rules and regulations notified, 22 Aug 2022, https://www.pib.gov.in/PressReleasePage.aspx?PRID=1853679
• Ministry of Law and Justice, Foreign Exchange Management Act, 1999 (section 13), linked from rbi.org.in, https://indiacode.gov.in/items/a972a617-5989-4b2c-a84f-617792137a57
• Ministry of Corporate Affairs, Companies Act, 2013, section 186, as hosted by the Income Tax Department, https://www.incometaxindia.gov.in/w/section-186-98
• Income Tax Department, Rule 220 of the Income Tax Rules, 2026, read 2 Oct 2026, https://www.incometaxindia.gov.in/w/rule-220-1
• Income Tax Department, Guidance note on Form 145, https://www.incometaxindia.gov.in/documents/d/guest/fn-145
• Income Tax Department, FAQs and guidance notes on forms under the Income Tax Rules, 2026, https://www.incometaxindia.gov.in/faqs-and-guidance-notes-on-forms-as-per-income-tax-rules-2026