Rule 115 of the Income Tax Rules 1962 — Foreign Currency Conversion Explained with Examples

By the CA team at GainSutra · Updated August 2026 · 9 min read · Covers Rule 115 and its successor, Rule 206 of the Income-tax Rules, 2026

Every filing season the same working paper lands on my desk: foreign salary, RSU sales, a few dividends, all converted at whatever rate Google showed on the transaction date. The math is neat. The rate is wrong. Rule 115 of the Income Tax Rules 1962 prescribes exactly which rate converts foreign currency income into rupees — and, more importantly, exactly which date's rate.

Rule 115(1) — the operative text: "The rate of exchange for the calculation of the value in rupees of any income accruing or arising or deemed to accrue or arise to the assessee in foreign currency or received or deemed to be received by him or on his behalf in foreign currency shall be the telegraphic transfer buying rate of such currency as on the specified date." The Explanation then fixes a different specified date for each head of income, and borrows the TT buying rate definition from Rule 26.

Three Things Rule 115 Actually Says

1. TT Buy, not TT Sell. SBI's daily forex card lists several rates per currency — TT Buy, TT Sell, Bill rates, card rates. The rule uses the telegraphic transfer buying rate: what SBI pays to buy your currency. It usually sits below the Google mid-market number, and on a ₹40 lakh RSU sale a rupee of difference moves the gain by tens of thousands.

2. The date is fixed by law, not by your bank credit. For most income the specified date is the last day of the month before the month the income arose. Not the day the money landed. Not an average. When that last day has no published SBI card, practice is to step back to the last published one and note it in the file.

3. It covers accrued income, not just received income. RSU vesting is a salary perquisite under Section 17(2) the moment it vests, whether or not you sold a share. The vest-month conversion sets your cost of acquisition for every future capital gain on those shares.

Rule 115 Becomes Rule 206 from FY 2026-27

From 1 April 2026 the Income-tax Act, 2025 replaces the 1961 Act, and the Income-tax Rules, 2026 replace the 1962 Rules. The conversion rule is renumbered: Rule 115 becomes Rule 206, and the TT buying rate definition moves from Rule 26 to Rule 207. The mechanism is identical — same SBI rate, same specified dates. Income of FY 2025-26 and earlier cites Rule 115; FY 2026-27 onward cites Rule 206. The side-by-side mapping is on our SBI TT rates page.

The Dates That Matter, By Income Type — With Examples

"Specified date" is the whole game. Here is the mapping for the income that shows up in foreign-equity filings, each with a worked example using the month-end rates published on our free rates page:

IncomeSpecified date (rate to use)Example
Salary, incl. RSU / ESOP perquisite at vestingLast day of the month immediately preceding the month the salary fell due (or was paid in advance or arrears)RSUs vest 15 Feb 2026 → 31 Jan 2026 USD TT buy, ₹91.35
Dividend from a foreign companyLast day of the month immediately preceding the month the dividend was declared, distributed or paidDividend paid 18 Nov 2025 → 31 Oct 2025 rate, ₹88.20
Capital gains — sale considerationLast day of the month immediately preceding the month of transferShares sold 15 Apr 2026 → 31 Mar 2026 rate, ₹93.15
Capital gains — cost of acquisition (bought / vested in foreign currency)Same logic, applied at the month of purchase or vestingShares vested 10 Sep 2025 → last published Aug 2025 card (30 Aug), ₹87.70
Foreign bank interest (other sources)31 March — the last day of the previous year, one rate for the whole yearInterest credited through FY 2025-26 → 31 Mar 2026 rate, ₹93.15
Any of the above where TDS appliedProviso overrides: rate on the date tax was required to be deductedUS broker withheld tax on a 10 Nov 2025 dividend → TT buy of 10 Nov 2025 itself, not month-end
Foreign tax credit (Rule 128, Form 67)TT buying rate on the date the foreign tax was actually paidForeign tax paid 10 Nov 2025 → TT buy of 10 Nov 2025 for the Form 67 credit

Two rows trip people up constantly. Foreign bank interest is not "interest on securities" — it falls under other sources and takes one 31 March rate for the whole year, not twelve month-end rates. And the cost side of a capital gain has its own date, at the month of purchase, not the month of sale: a share vested in September 2025 and sold in February 2026 uses two different SBI rates in the same computation.

How Rule 115 Runs Through an RSU's Life

TransactionRule 115 rate dateUsed for
RSU vesting (perquisite income)Last day of month preceding the vest monthSalary perquisite; sets cost of acquisition for future capital gains
RSU sale (capital gains)Last day of month preceding the sale monthSale consideration in INR for Schedule CG
Dividend receivedLast day of month preceding the payment monthDividend income in INR; Form 67 computation
Schedule FA A3 — initial valueRate on the day of investmentInitial investment value in Schedule FA

Schedule FA Runs on Its Own Calendar

Schedule FA reports foreign assets held during the calendar year ending 31 December, not the financial year. Its conversion dates are its own: initial investment at the investment-date rate, peak balance at the rate on the date the peak occurred, closing balance and income at the 31 December rate. For calendar year 2025 that closing rate is the 31 Dec 2025 USD TT buy of ₹89.47, straight off our rates page.

The Traps

TT Sell is not TT Buy. I have seen working sheets built on the Sell column that overstated income on every line.

Yen is quoted per 100 units. An SBI card showing 55.00 against JPY means ₹55 per 100 yen. Skip the division and your income is a hundred times too large. Thai Baht follows the same convention.

Month-ends fall on Sundays. No CBDT circular prescribes a fallback. The defensible practice is the last preceding published card, applied consistently and noted in the working papers.

Averages are not a thing. The rule names one date per income item. An annual average has no basis in Rule 115 or Rule 206, however tidy the spreadsheet looks.

The RBI reference rate is not this rate. The RBI stopped publishing it in 2018; FBIL computes a benchmark now. Neither is what the rule asks for. In scrutiny, "SBI TT buy, 31 January 2026, per Rule 115" is an answer. "Google" is not.

Why Getting This Wrong Matters

Under Section 270A of the Income Tax Act, under-reporting of income attracts a penalty of 50% of the tax on the under-reported amount — 200% where it amounts to misreporting. A wrong conversion rate on a large RSU sale is exactly the kind of gap that surfaces in scrutiny, because the AO can recompute it from public data in minutes. And skipping Schedule FA is costlier still: Section 43 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 carries a ₹10 lakh penalty for failing to disclose a foreign asset in the return, even where the income itself was fully taxed.

Rule 115 applied automatically

GainSutra maintains the month-end SBI TT Buy series and applies the correct Rule 115 rate to every vest, sale and dividend in your broker statement — Fidelity, Schwab, Morgan Stanley, EquatePlus, Computershare, Merrill, UBS — without manual lookup.

Calculate with Correct Rates →
Does Rule 115 apply to both cost of acquisition and sale price?
Yes. Both convert under Rule 115, at different dates: cost at the last day of the month before acquisition (vesting), sale consideration at the last day of the month before the sale. One computation, two rates.
Is Rule 115 the same for all foreign currencies?
Yes — USD, EUR, GBP, AUD, SGD and the rest all use the SBI TT buying rate for that currency on the specified date. Convert EquatePlus EUR statements at the direct EUR rate, never via USD — we covered that in the EquatePlus guide. And watch JPY, which SBI quotes per 100 units.
Do I use TT Buy or TT Sell?
TT Buy — under Rule 115 today and Rule 206 from FY 2026-27. Bill rates, card rates and TT Sell have no role in the conversion.
Which rate applies to Schedule FA closing balance?
The 31 December TT buying rate. Peak balance takes the rate on the date the peak occurred; initial investment value takes the investment-date rate.
What if SBI published no rate on my specified date?
Step back to the last date SBI published a TT buy rate, apply it consistently, and record which date you used. There is no prescribed fallback, so consistency plus documentation is the defence.
Can I just use the Google rate?
No. Google shows an interbank mid-market rate; the rule requires SBI's published TT buying rate on a specific date. They differ, and only one has legal backing when the AO asks which rate you used and why.