Discuss the exclusions provided from the provisions of GAAR.

Rule 10U of the Income-tax Rules, 1962 'the Rules' provides for certain exclusions from the provisions of GAAR, which are as follows:- An arrangement where the tax benefit in the relevant assessment year arising, in aggregate, to all the parties to the arrangement does not exceed a sum of ₹ 3 crore; A Foreign Institutional Investor, who is an assessee under the Income-tax Act, 1961, and has not taken benefit of an agreement referred to in section 90 or section 90A as the case may be; and has invested in listed securities, or unlisted securities, with the prior permission of the competent authority, in accordance with the Securities and Exchange Board of India (Foreign Institutional Investor) Regulations, 1995 and such other regulations as may be applicable, in relation to such investments; A non-resident, in relation to investment made by him by way of offshore derivative instruments or otherwise, directly or indirectly, in a Foreign Institutional Investor; 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 investments made before the [1st day of April, 2017] by such person.