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TMI Blog
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GAAR carve-out for pre-2017 investment transfers clarified under amended income-tax rules.

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Full Text of the Document

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....Rule 128 of the Income-tax Rules, 2026 is amended to exclude from Chapter XI any income from transfer of investments made before 1 April 2017 by the same person, where such income accrues, arises, or is deemed to accrue, arise, or be received. The amended rule also clarifies that Chapter XI applies to arrangements regardless of when entered into if the tax benefit is obtained on or after 1 April 2017, except for the specified pre-2017 investment transfer income. The amendment comes into force on 1 April 2026.....