Under the Income-tax Act, 2025 and the Income-tax Rules, 2026, for tax year 2026-27 the general anti-avoidance rule can apply to an arrangement only if the aggregate tax benefit to all the parties…

The Income-tax Rules, 2026, continuing the old rule 10U, exclude from the general anti-avoidance rule any arrangement whose aggregate tax benefit to all parties in the relevant tax year does not exceed ₹3 crore. ₹1 crore is the primary-adjustment threshold for secondary adjustment in transfer pricing, and ₹20 crore is the specified-domestic-transaction threshold, not the GAAR limit.