"This amendment is a welcome and timely clarification from CBDT - perhaps even a rare 1st  April gift to the market. It expressly confirms that GAAR will not apply to income arising on transfer of investments made before 1 April 2017, even if the exit occurs later. This appears to address the uncertainty that emerged after the recent Tiger Global ruling on GAAR grandfathering. While Tiger Global may remain relevant on broader questions of substance and treaty abuse, this amendment materially reduces its relevance on the issue of GAAR grandfathering for pre-1 April 2017 investments. In effect, CBDT has realigned the rule text with the original grandfathering intent. That should provide comfort to long-term investors, especially offshore funds and legacy structures, and reduce avoidable controversy on exits."