What CBDT’s 31 March 2026 Notifications Mean For Live And Upcoming Exits

I. Introduction

India’s General Anti-Avoidance Rule (“GAAR”) framework has long rested on a critical assurance to investors: investments made prior to 1 April 2017 would remain outside the scope of GAAR scrutiny. For nearly a decade, this grandfathering protection was widely understood to extend to gains realised on the eventual transfer of such investments, irrespective of when the exit occurred.

That settled understanding was significantly disrupted by the Supreme Court’s decision in Tiger Global in January 2026. The judgment raised concerns that while the underlying investment may have been grandfathered, the broader holding structure through which the investment was made could nevertheless be subjected to GAAR review at the time of exit. The resulting uncertainty created immediate implications for ongoing transactions, particularly for funds holding legacy investments through treaty-based jurisdictions such as Mauritius and Singapore.