Section 47(viia) - Any transfer of bonds or GDR referred to in Sec. 115AC, made outside India by a Non-Resident to another Non-resident

Section 47(viia) exempts non-resident transfers of bonds and GDRs outside India from capital gains tax.

Section 47(viia) of the Income Tax Act specifies that any transfer of bonds or Global Depository Receipts (GDRs), as referred to in Section 115AC, conducted outside India between non-residents is not considered a transfer for capital gains tax purposes. This provision ensures that such transactions, involving non-resident transferors and transferees and capital assets like bonds and GDRs, are excluded from the definition of transfer under sections 2(47) and 2(14) of the Act, thereby exempting them from capital gains tax obligations.