Non-repatriable share issuance excludes such holdings from foreign investment, so no FLA filing obligation follows.

Shares allotted to a non-resident on a non-repatriable basis are not treated as foreign investment under the Annual Return on Foreign Liabilities and Assets framework of FEMA 1999; therefore, an entity whose only foreign shareholdings are non-repatriable allotments is not required to file the FLA return, the reporting obligation hinging on the repatriability characteristic of the issuance.

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