https://www.taxtmi.com/caselaws?id=788983 A compulsory transfer of funds to the Central Government under section 23(2) of the Export-Import Bank of India Act, 1981 was not a distribution of profit to shareholders and therefore did not constitute dividend. Dividend, in its ordinary and statutory sense, presupposes share capital and shareholders, which were absent on these facts. As the transfer was a statutory and mandatory payment rather than a shareholder distribution, section 115-O dividend distribution tax was inapplicable and the amount was not taxable as dividend under section 2(22) of the Income-tax Act, 1961. en-us Mon, 30 Mar 2026 00:00:00 +0530 Wed, 01 Apr 2026 07:51:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788983 A compulsory transfer of funds to the Central Government under section 23(2) of the Export-Import Bank of India Act, 1981 was not a distribution of profit to shareholders and therefore did not constitute dividend. Dividend, in its ordinary and statutory sense, presupposes share capital and shareholders, which were absent on these facts. As the transfer was a statutory and mandatory payment rather than a shareholder distribution, section 115-O dividend distribution tax was inapplicable and the amount was not taxable as dividend under section 2(22) of the Income-tax Act, 1961. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788983