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NOSTRO Interest: Mutuality Principle Applies to Transactions with Own Head Office/Branches, Not with External Entities.
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....There is a clear distinction between the NOSTRO interest earned/paid by the assessee from/to its own Head office/overseas branches and NOSTRO interest paid/earned to/from other than assessee's own Head office or branches. Whereas in the first situation, the principle of mutuality will apply and in the later case it will not. - AT....
TaxTMI
TaxTMI