Tax exemption for cross-border share transfers in amalgamation permitted where shareholder continuity and no foreign taxation applies. The amendment exempts from capital gains tax transfers in a scheme of amalgamation where shares in an Indian company move from an amalgamating foreign company to the amalgamated foreign company provided shareholder continuity is maintained and the transfer is untaxed in the amalgamating company's country; it also exempts offshore transfers of specified bonds or shares between non-residents; and it expands the conversion provision to cover bonds as well as debentures, deemed effective from the earlier operative date.