Case Law Analysis
|Income Tax Appellate Tribunal
Section 9(1)(v)(c) IT Act | Interest from Nostro Accounts Not Taxable Under Mutuality Principle : ITAT Mumbai
ITAT Mumbai rules that interest earned by Indian branches of foreign banks from their head office or overseas branches is not taxable under Section 9(1)(v)(c) of the Income Tax Act, as it constitutes payment to self rather than income. The decision reinforces the mutuality principle, shielding such transactions from domestic tax liability for foreign banks operating in India.