Mandatory statutory transfers of funds to the Central Government...

Mandatory statutory transfers of funds to the Central Government under section 23(2) of the Exim Act were treated as not constituting dividend, so section 115-O dividend distribution tax did not apply. The Tribunal followed its coordinate bench decision in the assessee's own later years, noted that the Revenue showed no change in facts or law, and upheld deletion of the tax demand. The Revenue's appeals for all years were dismissed.