The Mumbai Bench of India's Authority for Advance Rulings (AAR) recently issued a ruling on the grandfathering of the beneficial treatment of gains from the alienation of shares under the 1982 India-Mauritius tax treaty. Prior to its amendment by a 2016 protocol, the treaty granted exclusive taxation rights on capital gains to the country of residence of the seller and did not include a limitation on benefits clause. The amendment of the treaty grandfathered and preserved for the residence co…