The Income Tax Department has explicitly excluded income arising from transfer of investments

made prior to April1,2017, from the ambit of General Anit 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.