ipcc

Dear Sec 47(iii) refers to Transfer of capital assets by gift, and the transfer is not treated as transfer if the below cond. r fulfilled:

1) under gift;

2)under will; or

3)under an irrevocable transfer.

Here sec 47 (viia) will come in force which says that Transfer of foreign currency convertible bonds or GDR by a Non-residen to another Non-resident is not treated as "Transfer"

and under sec 47(viia) 4 conditions r given and d above que fulfills all the four conditions.