Indirect transfer exemption: redemption of upstream interests outside India excluded where underlying India transfer is taxed and proceeds are pro rata. The circular provides that indirect transfer provisions will not apply to income of a non-resident on redemption or buyback of indirect holdings where that income arises from a transfer of shares or securities held in India by specified funds and is chargeable to tax in India, provided the non-resident's proceeds do not exceed its pro rata share of the total consideration realized by the specified funds; direct investors in the specified funds remain taxable under the extant law.