No Tax on on transfer of shares of Indian subsidiary to Singapore subsidiary without consideration on account of reorganisation by American company

Deere and Co., In re Authority for Advance Rulings, New Delhi AAR No. 934 of 2010 Decided on: 27 May 2011 Ruling J. Khosla, Member 1. The applicant, Deere and Company, USA, is a foreign company incorporated under the laws of the USA. It has worldwide subsidiaries. It provides advanced products and services for agriculture, forestry, construction, lawn and turf care, landscaping and irrigation. The Deere Group also provides financial services worldwide and manufactures and markets engines used in heavy equipments. John Deere India Private Limited (JDIPL) is a company incorporat...