GAAR amendments strengthen certainty for pre-April 2017 foreign investors

India has taken a decisive step to reinforce tax certainty for foreign investors. On 31 March 2026, the Central Board of Direct Taxes (CBDT) issued two notifications amending the General Anti-Avoidance Rules (GAAR). The changes confirm that income from the transfer of investments made before 1 April 2017 will not be subject to GAAR, regardless…