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India: Amendment clarifying GAAR grandfathering rules

Amended to clarify that GAAR provisions do not apply to income from transfers of investments made prior to April 1, 2017

April 3, 2026

The Central Board of Direct Taxes (CBDT) issued two notifications—one in relation not the 1962 Income Tax Rules and the other in relation to the 2026 Income Tax Rules—amending the grandfathering rules under the general anti avoidance rule (GAAR) provisions to clarify that such provisions do not apply to income arising from a transfer of investments prior to April 1, 2017.

The amendment was in response to the Supreme Court’s decision in the Tiger Global case.

Read an April 2026 report prepared by the KPMG member firm in India

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