Held dismissing the appeal, that for the assessment year 2003-04, the assessee was not entitled to exemption of dividend income in the absence of section 10(33) of the Act (section 10(33) of the Act was omitted by the Finance Act, 2002). Moreover, the contention of the assessee that the payment of Rs. 25 lakhs was in the nature of capital in view of the fact that the company was under liquidation proceedings, and that such distribution was taxable in accordance with section 46(2) of the Act was not tenable, because the dividend was declared before liquidation and dividend distribution tax was paid under section 115-O of the Act by the company (dividend was declared on July 5, 1999 and dividend distribution tax was paid on January 31, 2001. Order of CIT(A) is affirmed. (AY. 2003-04)