{"id":1405,"date":"2026-04-07T05:20:58","date_gmt":"2026-04-07T05:20:58","guid":{"rendered":"https:\/\/theleagle.in\/?p=1405"},"modified":"2026-04-07T05:20:59","modified_gmt":"2026-04-07T05:20:59","slug":"amendments-to-the-it-rules-2026-effectuating-the-tiger-global-case","status":"publish","type":"post","link":"https:\/\/theleagle.in\/?p=1405","title":{"rendered":"Amendments to the IT Rules, 2026: Effectuating the Tiger Global Case\u00a0"},"content":{"rendered":"
<\/div>\n

On 31st<\/sup> March 2026, the Central Board of Direct Taxes (\u2018CBDT\u2019) notified amendment to two sub-rules of Rule 128, The Income Tax Rules, 2026 (\u2018IT Rules, 2026\u2019). Reactions to the amendments are neatly divided: while a few believe that the amendments are to effectuate the Supreme Court\u2019s decision in The Authority for Advance Rulings (Income Tax) and Others v Tiger Global International II Holdings<\/a> (\u2018Tiger Global case\u2019), others have observed that the amendments are to dilute its impact. In this article, I suggest that the CBDT has amended the IT Rules, 2026 to codify the ratio of Tiger Global case. Though before I elaborate on my claim, three preliminary things: <\/p>\n\n\n\n

Firstly, in this article I\u2019ve not elaborated either facts or the Supreme Court\u2019s decision in the Tiger Global case; for context, you can read my preliminary comments on the case<\/a>. <\/p>\n\n\n\n

Secondly, before reading this article you may want to look at the side-by-side comparison of the pre-amendment and post-amendment rules<\/a>.<\/p>\n\n\n\n

Thirdly, Rule 10U, IT Rules, 1962 is pari materia with Rule 128, IT Rules, 2026. Former was the subject of discussion in the Tiger Global case and latter, as its successor, is the subject of recent amendments discussed in this article.      <\/p>\n\n\n\n

In this article, my first claim is that amendments to the IT Rules, 2026 have been introduced to eliminate any confusion about the applicability of General Anti-Avoidance Rules (\u2018GAAR\u2019) to investments made before 1st<\/sup> April 2017. A confusion that was partly caused by use of the phrase \u2018without prejudice\u2019 in Rule 10U(2), Income Tax Rules, 1962 (\u2018IT Rules, 1962\u2019). I underline this claim by analyzing relevant portions of the Delhi High Court\u2019s judgment<\/a> that was overruled by the Supreme Court in the Tiger Global case. My second claim is that amendment to the IT Rules, 2026 brings greater clarity about the Income Tax Department\u2019s (IT Department) stance on the interaction of GAAR with Double Taxation Avoidance Agreement (\u2018DTAA\u2019) benefits. Specifically, the India-Mauritius DTAA. However, the Supreme Court\u2019s interpretation of cut-off date in the Tiger Global case has not been diluted by the amendment. Finally, a crucial piece of the puzzle is still missing. We still do not know judicial meaning of the term \u2018arrangement\u2019 \u2013 and by extension impermissible avoidance arrangement – despite the Supreme Court relying on it to decide the Tiger Global case. Thus, despite the amendments to the IT Rules, 2026, the crucial test of applying Rule 128 to facts will determine the tax fate of future investments. And the tax fate may, in most cases, hinge on how courts interpret the term arrangement.    <\/p>\n\n\n\n

Grandfathering of Investments  <\/strong><\/p>\n\n\n\n

Grandfathering in the IT Rules, 2026 is rooted in grandfathering in the India-Mauritius DTAA. Originally, an import of Article 13(4) of the India-Mauritius DTAA was that capital gains earned by a resident of Mauritius from securities listed in Indian stock exchanges were taxable only in Mauritius, the state of residence. While the vice-versa was also true, it mainly benefited companies incorporated in Mauritius aiming to access the Indian stock market. In 2016, Protocol to the India-Mauritius DTAA amended Article 13 – inserted Article 13(3A) – to provide taxation rights to the source country. Implying that India now had taxation rights on capital gains earned by companies incorporated in Mauritius. But Article 13(3A) was to be only applicable to gains from alienation of shares acquired on or after 1st<\/sup> April 2017. Article 13(3A) thus grandfathered investments and taxability of securities acquired before 1st<\/sup> April 2017 which were to be governed by the original provision. <\/p>\n\n\n\n

Rule 10U(1) of the IT Rules, 1962 intended to achieve the same effect as Article 13(3A) of the India-Mauritius DTAA, but in relation to GAAR. Specifically, Rule 10U(1)(d) provided that GAAR shall not apply to any income that arises, accrues, is received or deemed to accrue, arise or received by any person from transfer of investments made before 1st<\/sup>April 2017 by such person. However, Rule 10U(2) stated that: <\/p>\n\n\n\n

Without prejudice to the provisions of clause (d) of sub-rule (1)<\/u><\/em>, the provisions of Chapter X-A shall apply to any arrangement<\/u>, irrespective of the date on which it has been entered into, in respect of the tax benefit obtained from the arrangement on or after the 1st<\/sup> day of April, 2017. <\/em>(emphasis added)<\/p>\n\n\n\n

A combined reading of Rule 10U(1) and 10U(2) suggested that while grandfathering benefit was available for investments, arrangements could not claim the same benefit. But this was not the only possible interpretation. Use of the phrase \u2018without prejudice\u2019 created room to suggest that Rule 10(2) did not completely override Rule 10U(1)(d). And it is on this specific point that the Delhi High Court made a few pertinent observations.    <\/p>\n\n\n\n

\u2018Without Prejudice\u2019 in the IT Rules, 1962 <\/strong><\/p>\n\n\n\n

The IT Department argued before the Delhi High Court that \u2018without prejudice\u2019 clause implies that Rule 10U(2) overrides Rule 10U(1)(d). Even though an arrangement may have been entered before 1st<\/sup> April 2017, any benefit obtained from it after 1st<\/sup> April 2017 will be subject to GAAR. On the other hand, the counsel for Tiger Global resisted the IT Department\u2019s interpretive approach, and argued that use of \u2018without prejudice\u2019 cannot permit interpreting Rule 10(2) inconsistently with Rule 10U(1)(d).  <\/p>\n\n\n\n

The Delhi High Court refused to accept the IT Department\u2019s argument and observed that: <\/p>\n\n\n\n

Apart from the above, if the argument of Mr. Srivastava were to be accepted, it would amount to sub-rule (2) immediately taking away what stood saved in the immediately preceding provision, namely, clause (d) of sub-rule (1). If the submission of Mr. Srivastava were to be upheld, it would lead to a wholly irreconcilable conflict between the two aforenoted provisions. However, the arguments addressed along the aforesaid lines are clearly erroneous since it fails to consider the meaning liable to be ascribed to the expression \u2015without prejudice to<\/u>\u2026..which appears in sub-rule (2). <\/em>(para 231) (emphasis added)<\/p>\n\n\n\n

The Delhi High Court thus clearly stated that accepting the IT Department\u2019s argument would amount to Rule 10U(2) taking away the benefit conferred by Rule 10U(1)(d). Additionally, the High Court elaborated on the meaning of \u2018without prejudice\u2019 by relying on ITO v Gwalior Rayon Silk Manufacturing (Weaving) Co Ltd<\/a>. In short, the meaning of \u2018without prejudice\u2019 in the context of Rule 10U can be distilled as: (i) Rule 10U(2) cannot be inconsistent to or prejudicial to Rule 10U(1)(d); (ii) while Rule 10U(2) was an independent provision it was subject to Rule 10U(1)(d). <\/p>\n\n\n\n

Apart from the meaning of \u2018without prejudice\u2019, the Delhi High Court also invoked the grandfathering benefit introduced via Article 13(3A) of the India-Mauritius DTAA. The High Court observed that the India-Mauritius DTAA had clearly provided safe passage to transactions completed before 1st<\/sup> April 2017. And accepting the IT Department\u2019s argument that Rule 10U(2) overrides the grandfathering benefit provided in Rule 10U(1)(d) would mean:<\/p>\n\n\n\n

\u2026a delegatee of the Legislature while framing subordinate legislation being competent to override a treaty provision. A subordinate legislation would thus stand elevated to a status over and above a treaty entered into by two nations in exercise of their sovereign power itself. <\/em>(para 230)<\/p>\n\n\n\n

The Delhi High Court held that permitting secondary legislation to override international treaty obligations is unacceptable. Cumulatively, Article 13(3A) of the India-Mauritius DTAA and meaning of \u2018without prejudice\u2019 was used by the Delhi High Court to prevent the IT Department from invoking GAAR against Tiger Global. The High Court\u2019s observations on Rule 10U are an important reference point to understand interpretation of secondary legislation, meaning of the phrase \u2018without prejudice\u2019 and how DTAA obligations can and do influence domestic laws. <\/p>\n\n\n\n

Amendments Align with Ratio of the Tiger Global Case<\/strong><\/p>\n\n\n\n

The Supreme Court in the Tiger Global case overruled the Delhi High Court. The IT Department\u2019s stance before the Supreme Court can be summarized as: Rule 10U(1)(a) grants grandfathering benefit only to investments made before 1st<\/sup>April 2017 and not to arrangements entered before 1st<\/sup> April 2017. Thus, Rule 10U(2) can be applied to deny benefits to arrangements entered before the said date. The Supreme Court agreed with the IT Department and held that: <\/p>\n\n\n\n

Therefore, the prescription of the cut-off date of investment under Rule 10U(1)(d) stands diluted by Rule 10U(2), if any tax benefit is obtained based on such arrangement. The duration of the arrangement is irrelevant<\/em>. (para 46)<\/p>\n\n\n\n

It stands to reason that the Supreme Court interpreted \u2018without prejudice\u2019 to have same meaning as \u2018notwithstanding\u2019. And, by doing so, clarified that the relationship of Rule 10U(2) with Rule 10U(1)(d) is that the former occupied a higher pedestal. It is to reinforce this legal position that Rule 128(2), IT Rules, 2026 has been amended to state that:<\/p>\n\n\n\n

The provisions of Chapter XI shall apply to any arrangement, irrespective of the date on which it has been entered into<\/u>, in respect of the tax benefit obtained from the arrangement on or after the 1st April, 2017, except for that income which accrues or arises to, or deemed to accrue or arise to, or is received or deemed to be received by, any person from transfer of such investments which were made before the 1st April, 2017 by such person. <\/em>(emphasis added) <\/p>\n\n\n\n

There are two inter-related reasons why I suggest that the above amendment is to effectuate ratio of the Tiger Global case. Firstly, the removal of \u2018without prejudice\u2019 clause eliminates any confusion as to whether Rule 128(2) overrides Rule 128(1)(d). A confusion that was evident in the Delhi High Court\u2019s judgment which was not in favor of the IT Department. Secondly, Rule 128(2) now uses the word \u2018irrespective\u2019. This aligns with the new legislative policy under the IT Act, 2025 to use \u2018irrespective\u2019 instead of \u2018notwithstanding\u2019. If we tentatively understand that meaning of irrespective is equivalent to notwithstanding, then Rule 128(2) overrides Rule 128(1)(d). And it is the primacy of Rule 128(2) that the IT Department successfully argued before the Supreme Court in the Tiger Global case. <\/p>\n\n\n\n

Thus, I suggest that the IT Rules, 2026 now codify the Tiger Global ratio and not dilute it. Grandfathering benefit is available only to investments, not to arrangements. The date on which the arrangement was entered \u2013 before or after 1st <\/sup>April 2017 – is immaterial as GAAR can be invoked against all arrangements. <\/p>\n\n\n\n

No Change in Cut-Off Date<\/strong><\/p>\n\n\n\n

The Supreme Court in the Tiger Global case suggested that gains arising after cut-off date of 1st<\/sup> April 2017 cannot claim the grandfathering benefit. Supreme Court\u2019s observations on Rule 10U(1)(d) were that the cut-off date was for capital gains and not the investments. See, for example, the Supreme Court\u2019s following observation: <\/p>\n\n\n\n

\u2026 in the case at hand, though it prima facie appears as if the assessees acquired the capital gains before the cut-off date, i.e., 01.04.2017, it is to be noted that the proposal for transfer of investments commenced only on 09.05.2018<\/em>. (para 47)<\/p>\n\n\n\n

The Supreme Court is clearly concerned that capital gains were not earned by Tiger Global before the 1st<\/sup> April 2017 instead of determining if the investment was made before that date. The Supreme Court also elaborated that the underlying transaction was only completed after the 1st<\/sup> April 2017 to underline that capital gains were only earned after cut-off date. However, grandfathering \u2013 under the India-Mauritius DTAA and the IT Rules, 1962 – protected investments made before 1st<\/sup> April 2017 and did not require that income should be earned before the said date. Since Rule 10U(1)(d) and Rule 128(1)(d) contain substantially the same language the Tiger Global ratio is certainly not diluted by amendment to the IT Rules, 2026. Rule 128(1)(d) of the IT Rules, 2026 states that GAAR shall not apply to: <\/p>\n\n\n\n

any income accruing or arising to, or deemed to accrue or arise to, or received or deemed to be received by, any person from transfer of such investments which were<\/strong> made before the 1st April, 2017 by such person.\u201d;<\/em> (emphasis added) <\/p>\n\n\n\n

Rule 128(1)(d) clearly states that investments were made by a person before 1st<\/sup> April 2017 but the income transfer of such investments was realised after the said date, GAAR shall be inapplicable. Rule 10U(1)(d), reproduced below also stated the same: <\/p>\n\n\n\n

any income accruing or arising to, or deemed to accrue arise to, or received<\/em> or deemed to be received by, any person from transfer of investments made<\/strong><\/em> before the first day of April, 2017 by such person.<\/em>(emphasis added)<\/p>\n\n\n\n

The addition of \u2018which were\u2019 in the amended rule is hardly a substantive amendment. In the absence of any substantial difference between Rule 10U(1)(d) and Rule 128(1)(d), the Supreme Court\u2019s observations on cut-off date remain the law until their basis is removed by a statutory amendment or subsequent decision(s).  <\/p>\n\n\n\n

Meaning of \u2018Arrangement\u2019 May Continue to be Contentious <\/strong><\/p>\n\n\n\n

The above changes though still leave us searching for one crucial answer. The meaning of arrangement. GAAR is applicable only if the arrangement is an impermissible avoidance arrangement. The Supreme Court referred to the statutory definition of an impermissible avoidance arrangement \u2013 in Section 96, IT Act, 1961\/Section 179, IT Act, 2025 – which states that it is an arrangement whose main purpose is to obtain a tax benefit and is carried out by means or manner which is not ordinarily employed for bona fide purposes. In the Tiger Global case the Supreme Court stated that transaction in question was an impermissible avoidance arrangement because: the transaction entered by Tiger Global was exempt from tax under the Mauritius tax law and it was also seeking exemption under the Indian income tax law. Thereby presenting a strong case for the IT Department to deny the benefit under the India-Mauritius DTAA as such an arrangement is impermissible. <\/p>\n\n\n\n

The Supreme Court made no precise observation as to which aspect of the transaction or corporate structure\/arrangement adopted by Tiger Global amounts to an impermissible avoidance arrangement. The Supreme Court\u2019s above observations suggest that to claim tax benefit under a DTAA, the taxpayer must pay tax in at least one of the contracting states. And since the case involved an indirect transfer, the Supreme Court\u2019s observations can be applied to similar such transfers in the future. But, overall, specificity as to what constitutes an impermissible avoidance arrangement is missing in the Tiger Global case. Largely, we have the statutory definition of an impermissible avoidance arrangement to rely on for future cases, but the exact scope may emerge through future decisions and as new fact situations require judicial attention. <\/p>\n\n\n\n

Overall, though amendments to the IT Rules, 2026 have ensured that any confusion that could emerge from interpretation of the \u2018without prejudice\u2019 clause is removed. And the IT Department is intent on effectuating ratio of the Tiger Global case in so far as application of GAAR in relation to grandfathering benefit is concerned. In short, arrangements entered before 1st<\/sup> April 2017 will be subject to GAAR, only investments can claim the grandfathering benefit. But distinguishing one from the other will require strenuous efforts and contentious interpretations.      <\/p>\n\n\n\n

PS: Amendments to the IT Rules, 2026 were uploaded via a notification on the IT Department\u2019s website without any accompanying explanation. Taxpayers were left to their own devices to decode rationale and implication of the amendment. Perhaps the IT Department could have made some effort in communicating its intent.   <\/p>\n","protected":false},"excerpt":{"rendered":"

On 31st March 2026, the Central Board of Direct Taxes (\u2018CBDT\u2019) notified amendment to two sub-rules of Rule 128, The Income Tax Rules, 2026 (\u2018IT Rules, 2026\u2019). Reactions to the amendments are neatly divided: while a few believe that the amendments are to effectuate the Supreme Court\u2019s decision in The Authority for Advance Rulings (Income Tax) and … Read more<\/a><\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_themeisle_gutenberg_block_has_review":false,"cybocfi_hide_featured_image":"","footnotes":""},"categories":[137],"tags":[18,172,307,25,327,94,32,305],"class_list":["post-1405","post","type-post","status-publish","format-standard","hentry","category-there-are-two-certainties-in-life-taxes-and-complaints-about-taxes","tag-delhi-high-court","tag-gaar","tag-india-mauritius","tag-it-act-1961","tag-it-act-2025","tag-ravpratapsingh","tag-supreme-court","tag-tiger-global"],"yoast_head":"\nAmendments to the IT Rules, 2026: Effectuating the Tiger Global Case\u00a0 - TheLeagle | Eco Law Forum<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/theleagle.in\/?p=1405\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Amendments to the IT Rules, 2026: Effectuating the Tiger Global Case\u00a0 - TheLeagle | Eco Law Forum\" \/>\n<meta property=\"og:description\" content=\"On 31st March 2026, the Central Board of Direct Taxes (\u2018CBDT\u2019) notified amendment to two sub-rules of Rule 128, The Income Tax Rules, 2026 (\u2018IT Rules, 2026\u2019). 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