FC GPR for transfer of equity shares

When the shares are transferred by a resident to non resident, transferor needs to file Form FC TRS with RBI. The resident transferor being the subscriber to the memorandum of the company while incorporation.
Since the non resident is acquiring shares through transfer, the company forms no part in issuing and allotting the shares to the non resident.
In this case whether the company is required to file FC GPR to the RBI or not..?
Please suggest.