Notwithstanding anything contained in this Act or any other law for the time being in force, if in an income year, the amount of stock dividend declared or distributed exceeds the amount of cash dividend declared or distributed or stock dividend is declared or distributed without declaring or distributing any cash dividend by a company registered under Companies Act, 1994 (Act No. XVIII of 1994) and listed to any stock exchange, tax shall be payable at the rate of 10% (ten percent) on the whole amount of stock dividend declared or distributed in that income year.