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AIS, 26AS & TIS Reconciliation

Avoid Tax Notices — NRI Guide 2026

MW

CA Mayank Wadhera

CA | CS | CMA | IBBI Registered Valuer · MKW Advisors

Updated March 2026
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The Income Tax Department uses AIS as its primary scrutiny tool. NRIs must reconcile AIS, 26AS, and TIS before filing ITR. Common issue: NRE interest appearing as taxable — file feedback to correct it. Mismatches trigger notices under 148/143.

How the tax department uses AIS to catch mismatches, handling NRE interest in AIS, TDS credit verification, property sale reporting, and the 5-step reconciliation process.

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AIS, 26AS & TIS Reconciliation for NRIs — How to Avoid Tax Notices in 2026

By CA Mayank Wadhera (CA | CS | CMA | IBBI Registered Valuer) Founder, MKW Advisors | Legal Suvidha | DigiComply


The Income Tax Department no longer waits for you to file your return. It already knows your financial transactions — every mutual fund redemption, every property sale, every bank interest credit, every dividend received. The mechanism behind this all-seeing eye is the Annual Information Statement (AIS), and for NRIs, it is both a powerful tool and a dangerous trap.

For FY 2025-26 (AY 2026-27), the department has refined its data-matching algorithms significantly. If there is a mismatch between what appears in your AIS, Form 26AS, or Taxpayer Information Summary (TIS) and what you report in your ITR, an automated notice is almost guaranteed. For NRIs — who deal with exempt NRE interest, cross-border property transactions, and TDS at higher rates — the risk of mismatch is substantially higher than for resident taxpayers.

This guide walks you through every aspect of AIS, 26AS, and TIS reconciliation that an NRI must understand before filing their return for FY 2025-26.


What Is the Annual Information Statement (AIS)?

The Annual Information Statement (AIS) is a comprehensive record of all financial transactions linked to your PAN during a financial year. Introduced by the CBDT in November 2021 under Section 285BB of the Income Tax Act, the AIS replaced the older Form 26AS as the department's primary data source for taxpayer profiling and scrutiny.

What the AIS Captures

The AIS captures an extraordinarily wide range of financial data, including:

  • Salary income reported by your employer (even if the employer is in India and you are a non-resident)
  • Interest income from savings accounts, fixed deposits, recurring deposits — across all banks
  • Dividend income from shares and mutual funds
  • Sale and purchase of securities — equity shares, mutual fund units, bonds, debentures
  • Sale and purchase of immovable property — including stamp duty valuation and TDS deducted
  • Foreign remittances reported under the Liberalised Remittance Scheme (LRS) by banks
  • Cash deposits and withdrawals above specified thresholds
  • Credit card payments above Rs 10 lakh in a financial year
  • Rent received on property in India
  • Interest on tax refunds issued by the department
  • GST turnover (if applicable)
  • Off-market transactions in securities

For NRIs, the critical point is this: the AIS does not differentiate between taxable and exempt income at the data collection stage. It simply records everything. This means your exempt NRE Fixed Deposit interest of Rs 8 lakh will appear in the AIS alongside your taxable NRO Fixed Deposit interest of Rs 3 lakh — and the system may treat both as taxable unless you reconcile and file feedback.


What Is Form 26AS?

Form 26AS is your Tax Credit Statement. It has been the cornerstone of tax filing in India for over a decade, though its role has evolved significantly since the introduction of AIS.

What Form 26AS Contains (Post-2021 Changes)

After the AIS rollout, Form 26AS has been restructured to primarily focus on:

  • Part A: TDS deducted by deductors (employers, banks, tenants, buyers of property)
  • Part A1: TDS on income from Form 15G/15H (relevant for some situations)
  • Part A2: TDS on sale of immovable property (Section 194-IA)
  • Part B: Tax collected at source (TCS)
  • Part C: Tax paid (advance tax, self-assessment tax)
  • Part D: Refunds received during the financial year
  • Part F: Details of Specified Financial Transactions (SFT) — though this is now primarily in AIS
  • Part G: TDS defaults by deductors

Why 26AS Still Matters for NRIs

Even though AIS has taken over as the comprehensive data statement, Form 26AS remains the authoritative document for TDS credit claims. When you file your ITR and claim TDS credit of Rs 2,50,000 deducted on your property sale, the CPC at Bengaluru verifies this against 26AS — not AIS. If there is even a minor mismatch (wrong PAN, wrong assessment year, incorrect amount), your TDS credit will be denied, and your refund will be reduced or withheld.

For NRIs, who face TDS at elevated rates (20% on NRO FD interest, 12.5% on property sale above Rs 50 lakh, 30% on rental income), the TDS amounts involved are substantial. A mismatch on a Rs 1 crore property sale can mean a TDS credit denial of Rs 12.5 lakh or more.


What Is the Taxpayer Information Summary (TIS)?

The Taxpayer Information Summary (TIS) is the computed version of the AIS. While the AIS shows raw transaction-level data reported by various entities (banks, registrars, mutual fund houses, brokers), the TIS aggregates this data and presents a derived income figure for each category.

How TIS Differs from AIS

AspectAISTIS
Data typeRaw transaction dataAggregated/computed income
GranularityIndividual transaction levelCategory-level summary
PurposeTransparency and verificationPre-fill ITR, flag mismatches
Taxpayer feedbackYes, you can submit correctionsDerived value updates after AIS feedback
Reporting entitiesShows who reported the dataShows computed taxable value

The TIS Trap for NRIs

The TIS computes a "derived value" of your income in each category. For an NRI, this derived value can be dangerously incorrect. Consider this scenario:

  • Your NRE FD earned Rs 6,00,000 interest (exempt under Section 10(4)(ii))
  • Your NRO FD earned Rs 2,50,000 interest (taxable)
  • The TIS may show "Interest Income: Derived Value Rs 8,50,000"

If you simply accept this derived value and file accordingly, you will end up paying tax on Rs 6,00,000 of exempt income. If you file correctly showing only Rs 2,50,000 as taxable, the system will flag a mismatch against the TIS derived value — potentially triggering scrutiny.

The solution is to file AIS feedback BEFORE filing your ITR, marking the NRE interest as exempt. This is not optional for NRIs. It is essential.


Why Reconciliation Is Critical for NRIs

The Income Tax Department has made AIS the primary scrutiny tool for identifying underreported income. The Central Processing Centre (CPC) runs automated matching algorithms that compare your filed ITR against AIS data. Any discrepancy above a threshold triggers one of three outcomes:

  1. Section 143(1)(a) adjustment: The CPC automatically adjusts your tax liability based on AIS data, often adding back income you did not report (even if it was legitimately exempt).

  2. Section 133(6) enquiry: A formal information request asking you to explain the discrepancy. While not a full notice, ignoring it escalates the situation.

  3. Section 148 reassessment notice: The department reopens your assessment, believing income has escaped assessment. For NRIs, responding to a 148 notice from overseas is logistically nightmarish and legally complex.

NRI-Specific Reconciliation Risks

NRIs face reconciliation challenges that resident taxpayers do not encounter:

  • NRE/FCNR interest reported by banks appears in AIS as generic "interest income" without an exemption flag
  • Property sale TDS at 12.5% on the full consideration, even when the actual capital gain (after indexation) may be much lower or even a loss
  • Double-entry reporting: A property transaction may appear both as an SFT (Specified Financial Transaction) and as a TDS entry, inflating apparent income
  • Mutual fund capital gains computed by AIS without considering the correct cost of acquisition, especially for inherited or gifted units
  • Residential status confusion: Banks may report you as a resident taxpayer if your KYC has not been updated, leading to incorrect TDS rates and wrong categorization in AIS
  • NRO interest without DTAA benefit: TDS deducted at 20% instead of the treaty rate, requiring reconciliation at the claim stage

NRE Interest Appearing in AIS: How to Handle It

This is the single most common AIS issue for NRIs, and it catches thousands of taxpayers off guard every year.

The Problem

Banks report all interest payments to the Income Tax Department via SFT and TDS filings. When your NRE Fixed Deposit earns Rs 5 lakh in interest during FY 2025-26, the bank reports this Rs 5 lakh to the department. The AIS records it under "Interest from Deposits" without any exemption marker. The TIS then computes it as taxable interest income, inflating your derived income figure.

Under Section 10(4)(ii) of the Income Tax Act, interest earned on an NRE account or FCNR deposit is fully exempt from income tax, provided:

  • The individual is a Person Resident Outside India under FEMA (not just a non-resident under the Income Tax Act)
  • The account is a designated NRE or FCNR account maintained in accordance with FEMA regulations

The Solution: Step-by-Step

  1. Download your AIS from the income tax portal (detailed steps below)
  2. Identify the NRE interest entries under "Interest from Deposits"
  3. File AIS feedback for each NRE interest entry, selecting "Information is not fully correct" and providing the reason: "Interest on NRE Fixed Deposit — Exempt under Section 10(4)(ii)"
  4. In your ITR, report this income under "Exempt Income" (Schedule EI) — do NOT leave it unreported entirely
  5. Keep documentation ready: NRE FD certificate, bank statement showing NRE account type, FEMA residency proof

Critical warning: If your residential status under FEMA has changed (you have returned to India and your NRE account has been redesignated to RFC or resident account), the exemption may no longer apply. The date of status change is determinative, and interest earned after that date is fully taxable.


Property Sale in AIS: Reconciliation Requirements

When an NRI sells property in India, the transaction generates multiple data points in AIS and 26AS that must all align with the ITR.

What Appears in AIS for a Property Sale

  • Sale consideration as reported by the Sub-Registrar
  • Stamp duty value (which may differ from actual sale consideration)
  • TDS deducted by the buyer under Section 194-IA (12.5% of the consideration for properties above Rs 50 lakh)
  • SFT entry if the property value exceeds Rs 30 lakh

Common Mismatches

  1. Sale consideration vs. stamp duty value: Under Section 50C, if the stamp duty value exceeds the sale consideration by more than 10%, the stamp duty value is deemed as the full value of consideration for capital gains computation. Your AIS may show the stamp duty value, but you may have used the actual sale price in your ITR.

  2. TDS amount discrepancy: The buyer may have deducted TDS on the stamp duty value instead of the actual consideration, or may have deducted at the wrong rate. If the buyer filed Form 26QB late or with errors, the TDS may not even reflect in your 26AS.

  3. Multiple buyers/sellers: If the property was co-owned, the full sale consideration may appear in each co-owner's AIS, leading to apparent over-reporting.

  4. Lower TDS certificate (Section 197): If you obtained a lower TDS certificate because your actual capital gain was much lower than the consideration, the TDS in 26AS will be at the reduced rate — but the AIS will still show the full consideration, potentially creating an apparent mismatch.

Reconciliation Steps

  • Verify that the sale consideration in AIS matches your ITR (or file feedback explaining the difference)
  • Confirm TDS in 26AS matches the amount claimed in your ITR to the exact rupee
  • If the buyer has not deposited the TDS, pursue this with the buyer — you cannot claim credit for TDS not deposited with the government
  • Report the capital gain correctly (short-term or long-term based on holding period), using indexation where applicable for acquisitions before July 23, 2024

Mutual Fund Redemptions in AIS: Capital Gains Tracking

The AIS now captures every mutual fund redemption automatically, including the purchase date, sale date, sale value, and in many cases, the computed capital gain.

What NRIs Must Watch For

  • LTCG vs. STCG classification: For equity-oriented funds, units held for more than 12 months qualify for LTCG at 12.5% (with Rs 1.25 lakh exemption). For debt funds, all gains are taxed at slab rates regardless of holding period (for units purchased on or after April 1, 2023).
  • Grandfathering provisions: For equity MF units acquired before January 31, 2018, the cost of acquisition is the higher of the actual cost or the NAV as on January 31, 2018. AIS may not account for this correctly.
  • SIP redemptions: Each SIP installment is treated as a separate acquisition. A single redemption of SIP units may involve dozens of individual lots with different holding periods and costs. AIS may show a single lump sum.
  • TDS on MF redemption for NRIs: Mutual fund houses deduct TDS at 12.5% for LTCG and 30% for STCG on equity funds for NRIs. This TDS must match 26AS exactly.

Action Required

Download your Capital Gains Statement from each AMC (available on the AMC website or through CAMS/KFintech). Cross-verify every redemption entry in AIS against this statement. File feedback for any discrepancy.


TDS Mismatches: The Most Common Cause of Refund Delays

For NRIs, TDS mismatches between 26AS and ITR are the number one reason refunds are held up or denied. The CPC processes lakhs of returns automatically, and any TDS credit that does not perfectly match 26AS is simply rejected.

Common TDS Mismatch Scenarios for NRIs

ScenarioIssueImpact
Property saleBuyer files Form 26QB with wrong PAN or wrong assessment yearTDS credit denied entirely
NRO FD interestBank deducts TDS at 20% but files TDS return showing 10% (wrong section code)Partial credit only
Rental incomeTenant deducts TDS at 31.2% but does not file 26QC or files it lateTDS not visible in 26AS
Professional feesIndian client deducts TDS at 10% instead of the applicable rateAmount mismatch
Mutual fund redemptionAMC deducts TDS on gains but reports against wrong quarterTiming mismatch

How to Fix TDS Mismatches

  1. Check 26AS quarterly: Do not wait until filing season. Download 26AS in June, September, December, and March.
  2. Contact the deductor: If TDS is missing, ask the deductor (buyer, bank, tenant) to file or correct their TDS return.
  3. Request TDS certificate (Form 16A/16B/16C): This is your documentary evidence. Even if 26AS is wrong, having the certificate helps during assessment proceedings.
  4. File a grievance on TRACES: If the deductor is unresponsive, you can raise a ticket on the TRACES portal.
  5. Do NOT claim TDS credit that is not in 26AS: This is a common mistake. Claiming credit for TDS that does not appear in 26AS will result in your return being processed with a demand notice.

How to Access AIS: Step-by-Step on incometax.gov.in

Follow these steps to download and review your AIS for FY 2025-26.

Step 1: Log In to the Income Tax Portal

  • Visit incometax.gov.in
  • Click "Login" and enter your PAN as the User ID
  • Enter your password and complete OTP verification (sent to your registered mobile or email)

Step 2: Navigate to AIS

  • After login, go to "Services" in the top menu
  • Under the "AIS" section, click on "Annual Information Statement (AIS)"
  • Alternatively, navigate to: Services > AIS > Annual Information Statement

Step 3: Select the Financial Year

  • Select FY 2025-26 from the dropdown
  • The system will display your AIS in two formats:
    • Taxpayer Information Summary (TIS): The aggregated view
    • Annual Information Statement (AIS): The detailed transaction view

Step 4: Review Each Category

  • Click on each income/transaction category to see individual entries
  • Categories include: Salary, Interest, Dividend, Sale of Securities, Sale of Immovable Property, and others
  • For each entry, you will see the Reported Value and the Modified Value (if you have filed feedback)

Step 5: Download the AIS

  • Click the "Download" button
  • Choose JSON or PDF format (PDF is easier to review; JSON is useful for your CA)
  • Save this document — it is your reference for reconciliation

NRI-specific note: If you are accessing the portal from outside India, ensure you have a working Indian mobile number for OTP. If your mobile is deregistered, you will need to update it through the portal's profile section using Aadhaar-based OTP or by visiting a designated centre.


How to File AIS Feedback: Correct Wrong Information Online

Filing AIS feedback is the formal mechanism to tell the Income Tax Department that a particular entry in your AIS is incorrect, duplicate, or relates to exempt income. For NRIs, this is not a luxury — it is a necessity.

Step-by-Step Feedback Process

  1. Open AIS on the income tax portal (as described above)
  2. Click on the specific entry you want to provide feedback on
  3. Click the "Feedback" button next to the entry
  4. Select the appropriate feedback option:
    • "Information is correct" — if the data is accurate
    • "Information is not fully correct" — if the amount or details are wrong (provide the correct value)
    • "Information relates to other person/year" — if the transaction is wrongly attributed to your PAN
    • "Information is duplicate" — if the same transaction appears more than once
    • "Information is denied" — if you have no knowledge of the transaction (use with caution)
  5. Provide supporting remarks explaining the correction
  6. Submit the feedback

What Happens After You File Feedback

  • The AIS will show a "Modified Value" alongside the original "Reported Value"
  • The TIS derived income will be recalculated based on your feedback
  • The reporting entity (bank, registrar, etc.) may be notified to verify or correct their data
  • The feedback does NOT automatically amend the reporting entity's data — it simply records your position
  • During processing, the CPC will consider your modified values if they are reasonable and substantiated

Best Practice for NRIs

File AIS feedback for every entry that falls into these categories:

  • NRE/FCNR interest (mark as exempt under Section 10(4)(ii))
  • Duplicate property entries
  • Transactions that belong to a co-owner or family member
  • Incorrect amounts (verify against your bank/broker statements)
  • Income from a previous financial year incorrectly reported in the current year

High-Value Transactions: SFT Reporting and Its Impact on NRIs

Specified Financial Transactions (SFT) are high-value transactions that certain entities are required to report to the Income Tax Department under Section 285BA. These transactions automatically populate your AIS and form a critical part of the department's surveillance net.

SFT Reporting Thresholds Relevant to NRIs

TransactionReporting EntityThreshold
Purchase/sale of immovable propertyRegistrar/Sub-RegistrarRs 30 lakh or above
Time deposits (FDs)Banks/NBFCs/Post OfficeRs 10 lakh or above (aggregate in a year)
Cash deposits in savings accountBanksRs 10 lakh or above (aggregate in a year)
Cash deposits in current accountBanksRs 50 lakh or above (aggregate in a year)
Credit card paymentsCredit card issuersRs 10 lakh or above (aggregate in a year)
Purchase of shares/MF/bondsRegistrars, MF housesRs 10 lakh or above
Foreign currency saleAuthorized dealersRs 10 lakh or above
Purchase of bank drafts/pay ordersBanksRs 10 lakh or above (cash)

NRI-Specific SFT Concerns

  • NRE FD of Rs 10 lakh or more: Will be reported as an SFT, even though the interest is exempt. This does not make it taxable, but it will appear in your AIS and must be addressed.
  • Property purchase by NRI: Even if the property is being purchased (not sold), the transaction is reported and appears in the seller's AIS as well as yours.
  • Large repatriation transactions: Foreign currency sales through authorized dealers above Rs 10 lakh are reported — this is informational but can raise queries if not correlated with your declared income and source of funds.
  • Power of Attorney transactions: If a family member handles a transaction on your behalf through PoA, ensure the SFT is reported against the correct PAN.

Dividend and Interest Income Reconciliation

Dividend Income

Since the abolition of the Dividend Distribution Tax (DDT) from April 1, 2020, all dividends are taxable in the hands of the recipient at applicable slab rates. For NRIs:

  • TDS on dividends: Deducted at 20% (or lower treaty rate under DTAA) by the company or mutual fund
  • AIS reporting: Shows each dividend payment with the payer's name, TAN, and amount
  • Common error: Dividends from multiple demat accounts or from both physical and demat holdings may create duplicate entries
  • DTAA consideration: If you have claimed treaty benefits for lower withholding, the TDS rate in 26AS should match the treaty rate — not the default 20%

Interest Income

  • NRO savings/FD interest: Taxable, TDS at 30% (or treaty rate). Must be reported as "Income from Other Sources"
  • NRE savings/FD interest: Exempt under Section 10(4)(ii). Must appear in Schedule EI of the ITR
  • Interest on income tax refund: Taxable under "Income from Other Sources." Often overlooked by NRIs but always captured in AIS
  • PPF interest: Exempt, but if it appears in AIS, file feedback marking it as exempt
  • Interest on savings account: Deduction under Section 80TTA (up to Rs 10,000) is available only to residents, NOT to NRIs. Do not claim this deduction.

Reconciliation Action

Create a simple spreadsheet mapping every interest and dividend entry in your AIS to the corresponding entry in your bank/demat statement. Note the tax treatment (taxable/exempt) and TDS deducted. This spreadsheet becomes your working paper for ITR filing and is invaluable if a notice is received.


Common AIS Errors for NRIs

Based on our experience at MKW Advisors handling hundreds of NRI filings annually, these are the most frequently encountered AIS errors:

1. NRE Interest Shown as Taxable Interest

Frequency: Extremely common Cause: Banks report all interest under the same SFT category regardless of account type Fix: File AIS feedback marking it as exempt; report in Schedule EI of ITR

2. Wrong PAN Linkage

Frequency: Common, especially for property transactions Cause: Property buyer enters the wrong PAN in Form 26QB; joint account holders' transactions attributed to one PAN Fix: Contact the reporting entity to correct the PAN; file AIS feedback denying the transaction

3. Duplicate Entries

Frequency: Moderate Cause: Same transaction reported by multiple entities (e.g., bank reports FD interest AND files TDS return, creating two entries) Fix: File AIS feedback marking the duplicate as "Information is duplicate"

4. Transactions from Previous Financial Years

Frequency: Moderate Cause: Reporting entity files a late SFT or corrected TDS return, attributing a prior year's transaction to the current year Fix: File feedback selecting "Information relates to other person/year" and specify the correct year

5. Incorrect Sale Consideration for Property

Frequency: Common Cause: Sub-Registrar reports the stamp duty value instead of actual sale consideration; or reports the total value in each co-owner's AIS instead of their proportionate share Fix: File feedback with the correct proportionate value; retain the sale deed and registration documents as evidence

6. Residential Status Mismatch

Frequency: Occasional but high-impact Cause: Bank still has the NRI as "Resident" in their records, leading to wrong TDS rates and wrong reporting Fix: Update KYC with the bank immediately; request corrected TDS return

7. Crypto/Virtual Digital Asset Transactions

Frequency: Increasing Cause: Indian exchanges report all transactions including those by NRIs; P2P transactions may be incorrectly attributed Fix: File feedback if the transaction is incorrectly attributed; ensure correct reporting under Section 115BBH


Action Plan: 5-Step Reconciliation Process Before Filing ITR

Follow this systematic process to reconcile your AIS, 26AS, and TIS before filing your ITR for FY 2025-26.

Step 1: Download All Three Documents

  • Download AIS (PDF and JSON) for FY 2025-26
  • Download Form 26AS for FY 2025-26
  • Note the TIS derived values for each income category
  • Timeline: Complete by June 15, 2026 (AIS data is usually final by early June)

Step 2: Prepare Your Source Documents

Gather the following from all Indian financial institutions:

  • Bank statements (NRE, NRO, savings, FD maturity statements)
  • Capital gains statements from AMCs (CAMS/KFintech consolidated statement)
  • Property sale deed and registration documents
  • Form 16A (TDS certificates) from all deductors
  • Dividend statements from companies/registrars
  • Broker contract notes and profit/loss reports

Step 3: Line-by-Line AIS Matching

For each entry in the AIS:

  • Verify the amount against your source document
  • Verify the transaction date
  • Confirm whether the income is taxable or exempt
  • Check if TDS (if any) matches Form 26AS
  • Flag entries that are incorrect, duplicate, or relate to exempt income

Step 4: File AIS Feedback for All Discrepancies

  • Submit feedback for every incorrect or exempt entry (as detailed in the feedback section above)
  • Document the feedback reference number
  • Wait 48-72 hours for the TIS derived values to update
  • Re-download TIS to confirm the modified values are reflected

Step 5: File ITR with Full Reconciliation

  • Use the reconciled data as the basis for your ITR
  • Report exempt income in Schedule EI
  • Claim TDS credit only for amounts appearing in 26AS
  • Maintain a reconciliation workpaper (the spreadsheet from Step 3) for at least 7 years
  • Retain copies of all AIS feedback submissions

What Happens If You Do NOT Reconcile: Notices Under 148, 143(1)(a), and 133(6)

Ignoring AIS reconciliation is not an option. The department's automated systems are designed to catch mismatches, and the consequences escalate quickly.

Section 143(1)(a) — Intimation with Adjustment

This is the most common outcome. The CPC processes your return and finds that the income reported in your ITR is lower than the income in your AIS/TIS. It automatically adds the difference to your taxable income and issues an intimation with a tax demand.

Example: Your AIS shows Rs 8,50,000 in interest income (including Rs 6,00,000 of NRE interest). You correctly report only Rs 2,50,000 as taxable. But you did not file AIS feedback. The CPC adds back Rs 6,00,000, computes tax on Rs 8,50,000 at 30%, and sends you a demand of approximately Rs 1,87,200 (plus interest under Section 234A/B/C).

Response: You must file a rectification request under Section 154 within 30 days, attaching evidence that the NRE interest is exempt.

Section 133(6) — Information Request

The Assessing Officer (AO) sends you a letter asking for specific information about a transaction in your AIS that does not appear in your ITR. This is not a formal assessment proceeding, but failure to respond can trigger a full scrutiny assessment.

For NRIs: These letters are often sent to your Indian address on record. If you are overseas, you may miss the deadline entirely, leading to an adverse inference.

Section 148 — Reassessment Notice

If the AO believes that income has "escaped assessment" — meaning you did not report income that appears in your AIS — they can issue a notice under Section 148 to reopen your assessment. Under the amended provisions (post-Finance Act 2021), reassessment can be initiated:

  • Within 3 years from the end of the assessment year if escaped income is Rs 50 lakh or less
  • Within 5 years if escaped income exceeds Rs 50 lakh
  • Within 10 years if escaped income exceeds Rs 50 lakh AND the AO has evidence from a search, survey, or requisition

For NRIs, a 148 notice is particularly burdensome: it requires filing a return in response, engaging with the AO (often in person or through an authorized representative), and providing documentary evidence — all while being in a different country and time zone.

The Bottom Line

Reconciling your AIS, 26AS, and TIS before filing your ITR takes a few hours. Responding to a tax notice takes months, costs significantly in professional fees, and causes immense stress. The choice is clear.


The MKW Advisors Approach: AIS Reconciliation as the First Step in Every NRI Filing

At MKW Advisors, we have built our NRI tax practice on a simple principle: no ITR is filed without a complete AIS reconciliation first.

Our Process

  1. Day 1 — Data Collection: We download the client's AIS, 26AS, and TIS. We request bank statements, capital gains reports, and property documents from the client.

  2. Day 2-3 — Reconciliation Engine: Our team performs a line-by-line reconciliation of every AIS entry against source documents. We categorize each entry as: Verified Taxable, Verified Exempt, Incorrect (requires feedback), or Duplicate.

  3. Day 3-4 — AIS Feedback Filing: We file AIS feedback for every incorrect or exempt entry. We document every submission with reference numbers and screenshots.

  4. Day 5 — TIS Verification: After feedback processing, we re-download TIS and verify that the derived values now align with the correct taxable income.

  5. Day 5-7 — ITR Filing: Only after Steps 1-4 are complete do we prepare and file the ITR, ensuring perfect alignment between AIS, 26AS, TIS, and the filed return.

Why This Matters

In FY 2024-25, we processed NRI filings where AIS reconciliation identified and corrected:

  • Rs 47 lakh of NRE interest incorrectly showing as taxable across multiple clients
  • 23 cases of duplicate property entries inflating apparent income
  • 15 cases of TDS credit mismatches that would have resulted in refund denial
  • 8 cases of wrong PAN attribution for joint property transactions

Every one of these would have triggered a notice if left unaddressed.


Frequently Asked Questions (FAQs)

1. Is AIS reconciliation mandatory before filing ITR?

No, it is not legally mandatory. However, it is practically essential. The CPC uses AIS data as the primary matching tool during return processing. If your ITR does not align with your AIS, you will almost certainly receive a notice — either an intimation under Section 143(1)(a) or an information request under Section 133(6). Filing AIS feedback before your ITR ensures the department has your version of the facts on record before processing begins.

2. My NRE FD interest is showing in AIS. Will I be taxed on it?

Not automatically, but you must take action. NRE interest is exempt under Section 10(4)(ii) of the Income Tax Act, provided you are a Person Resident Outside India under FEMA. You must (a) file AIS feedback marking it as exempt, (b) report it under Schedule EI (Exempt Income) in your ITR, and (c) retain your NRE FD certificate and FEMA residency proof as documentation.

3. My property buyer deducted TDS but it is not showing in my 26AS. What do I do?

This typically means the buyer has not filed Form 26QB or has filed it with errors. Contact the buyer immediately and request that they file/correct the form. You cannot claim TDS credit until it appears in your 26AS. If the buyer is unresponsive, you may need to raise a grievance on the TRACES portal or approach your Assessing Officer.

4. I sold property jointly with my spouse. The full sale amount is showing in both our AIS statements. Is this correct?

No. The sale consideration should be split proportionate to ownership share. If each of you owned 50%, only 50% of the sale consideration should appear in your AIS. File AIS feedback for each of you, providing the correct proportionate amount and attaching the sale deed as reference.

5. Can I file my ITR before AIS data is fully updated?

Technically yes, but it is risky. AIS data for a financial year is typically complete by late May or early June of the following year. If you file your ITR before all reporting entities have submitted their data, you may face mismatches when new entries are added to your AIS later. We recommend waiting until at least mid-June before filing, and always checking AIS first.

6. What is the difference between "Reported Value" and "Modified Value" in AIS?

The "Reported Value" is the amount reported by the reporting entity (bank, registrar, AMC, etc.). The "Modified Value" is the value after you have filed AIS feedback. When you file feedback stating that the correct amount is Rs 2,50,000 instead of the reported Rs 8,50,000, the Modified Value will reflect Rs 2,50,000. The CPC considers the Modified Value during return processing.

7. I received a notice under Section 143(1)(a) because of an AIS mismatch. What should I do?

File a rectification request under Section 154 through the income tax portal within 30 days of receiving the intimation. Attach supporting documents proving that the AIS entry was incorrect or related to exempt income. If the rectification is not resolved satisfactorily, you can file an appeal before the Commissioner of Income Tax (Appeals) under Section 246A.

8. Are foreign income and foreign assets reported in AIS?

Foreign income earned outside India is generally not reported in AIS, as Indian reporting entities do not have visibility into foreign transactions. However, if you remitted funds to India through banking channels, the remittance may be captured. Foreign assets must be disclosed separately in Schedule FA (Foreign Assets) of the ITR — this is a separate compliance requirement under the Black Money Act, not related to AIS.

9. My AIS shows a mutual fund transaction I do not recognize. What should I do?

First, verify with your AMC by logging into the AMC portal or checking your CAMS/KFintech statement. If the transaction genuinely does not belong to you, file AIS feedback selecting "Information is denied." Also check whether a family member may have invested using your PAN inadvertently. If you suspect identity fraud or unauthorized use of your PAN, report it to the income tax department and SEBI immediately.

10. How long should I retain AIS reconciliation records?

Retain all reconciliation workpapers, AIS downloads, 26AS copies, feedback screenshots, and supporting documents for a minimum of 7 years from the end of the relevant assessment year. Under the amended reassessment provisions, assessments can be reopened up to 10 years in certain cases. Conservative retention of 10 years is recommended for high-value transactions.

11. Can my CA or tax advisor access my AIS on my behalf?

Yes. You can authorize your CA to access your income tax portal account by adding them as an "Authorized Representative" under the "My Account" section. Alternatively, you can share your login credentials securely — though this is less advisable from a security standpoint. At MKW Advisors, we use the authorized representative route for all our NRI clients.

12. Does filing AIS feedback guarantee that the CPC will accept my position?

No. Filing feedback records your position in the system, but the CPC retains the discretion to accept or reject it during processing. If the CPC does not accept your feedback and issues an adverse intimation, you will need to file a rectification or appeal. However, in our experience, well-documented feedback with clear reasoning is accepted in the vast majority of cases.

13. I have income from multiple countries. How does AIS handle DTAA credit?

AIS does not handle DTAA credit at all. It only records Indian-source transactions. The DTAA relief (under Section 90/91) is computed and claimed in the ITR itself, specifically in Schedule FSI (Foreign Source Income) and Schedule TR (Tax Relief). Your AIS reconciliation should focus on ensuring all Indian-source income and TDS are correctly reflected.


Take Control of Your AIS Before the Department Does

The days of filing a simple ITR based on Form 16 and bank statements are over. For NRIs with financial interests in India — property, investments, bank accounts — the AIS is the single most important document in your tax compliance toolkit. It tells you exactly what the department knows about you. Your job is to make sure what the department knows is accurate and complete.

Do not wait for a notice. Reconcile now.


Need expert help with AIS reconciliation and NRI tax filing for FY 2025-26?

MKW Advisors provides end-to-end AIS reconciliation and ITR filing services for NRIs across 30+ countries. Our team of qualified Chartered Accountants handles everything from AIS feedback to DTAA optimization.

Schedule a Consultation

WhatsApp: +91-96677 44073 Email: [email protected]

CA Mayank Wadhera is the Founder of MKW Advisors, Legal Suvidha, and DigiComply. He is a qualified Chartered Accountant (CA), Company Secretary (CS), Cost and Management Accountant (CMA), and IBBI Registered Valuer. He specializes in NRI taxation, cross-border structuring, and regulatory compliance for individuals and businesses with India-connected financial interests.

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CA Mayank Wadhera

CA | CS | CMA | IBBI Registered Valuer

Founder of MKW Advisors, specializing in NRI taxation, cross-border advisory, and capital gains planning. Part of the Legal Suvidha & DigiComply professional services ecosystem. Serving NRIs across 30+ countries.

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