Government security transfers between non-residents outside India are not regarded as transfers under the income tax framework. Transfer of a capital asset consisting of a Government security carrying periodic interest is not regarded as a transfer when made outside India through an intermediary dealing in settlement of securities and both transferor and transferee are non-residents. The current provision is section 70(1)(s) of the Income Tax Act, 2025, effective from 01.04.2026. The corresponding earlier provision is section 47(viib) of the Income Tax Act, 1961.