The Income Tax Department has explicitly excluded income arising from transfer of investments made prior to April 1, 2017, from the ambit of General Anti Avoidance Rules (GAAR), thus settling a long-standing industry concern regarding retrospective applicability.CBDT has amended Income-tax Rules, 2026, saying that any income accruing or received by any person from transfer of investments made before April 1, 2017, will not come under the GAAR.AKM Global Partner-Tax Sandeep Sehgal, said the amendment to Rule 128 of the Income-tax Rules, 2026 is largely clarificatory in nature and helps remove ambiguity around GAAR grandfathering.
