Income Tax Notification 54/2026 Dated 31/03/2026 – Amendment to Rule 10U to Protect Pre-2017 Investments from GAAR Applicability

 The amendment clarifies the applicability of Chapter X-A (General Anti Avoidance Rules – GAAR) concerning investments made before 1st April 2017, that any income arising from the transfer of such pre-2017 investments shall be excluded from the ambit of GAAR. While GAAR provisions will apply to tax benefits arising on or after 1st April 2017 irrespective of when the arrangement was entered into, an explicit exception has been carved out for income derived from the transfer of grandfathered investments. 

(Link: Income Tax Notification 54/2026 Dated 31/03/2026)

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