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<h1>Non-taxable transfers of offshore rupee bonds between non-residents exempted under section 47; preference-to-equity conversions excluded.</h1> The amendment inserts two exclusions to the definition of transfer: offshore transfers between non-residents of rupee denominated bonds of Indian companies issued outside India; and conversion of preference shares into equity of the same company, neither of which will be regarded as transfer for capital gains purposes, with prospective effect applying to the relevant assessment years.