Capital gains treatment for offshore non-resident transfers of bonds and GDRs remains excluded from transfer taxation. Transfer of bonds or Global Depository Receipts by a non-resident to another non-resident, when made outside India, is treated as a transaction not regarded as a transfer for capital gains purposes. The provision applies to the relevant bonds or GDRs and is confined to non-resident transferor and non-resident transferee situations. The transferee's cost is linked to the prevailing market price on a recognised stock exchange on the date the redemption request is made.