Whether the clients liable to tax in India on the capital gains and if yes, whether the bank is required to deduct tax at source on the remittance?

ADIT (International Taxation)-3(1) Vs. ICICI Bank Ltd. (ITAT Mumbai)- The issue in this appeals is with reference to the capital gains arising to various persons of Indian origin or non-resident Indians residing in UAE, who are clients of the Bank. These clients have invested in Government of India T-Bills, which has a tenure of 364 days. The T-Bills are also transferable before maturity. The clients purchased and sold these T-Bills during the year for which Bank, according to the guidelines of the RBI has opened a second subsidiary general ledger in their own name on behalf of their constitu...