(f)in case of assets mentioned in clause (a), if––(i)there is a transfer outside India of any share of, or interest in, a company or an entity registered or incorporated outside India by a non-resident transferor; and(ii)all the assets owned, directly or indirectly, by that company or entity are not located in India,then, the income referred to in sub-section (2) shall be only such part of the income as is reasonably attributable to assets located in India and determined in the manner, as may be prescribed;