Head office expenditure deduction for non-residents limited by percentage of adjusted income, with averaging rules for prior years.

Deduction of head office expenditure incurred outside India by a non-resident is allowed against profits and gains of business or profession attributable to India, subject to a cap equal to five percent of the adjusted total income (or, if adjusted total income is a loss, five percent of the average adjusted total income calculated over up to three preceding years). The provision defines adjusted total income for this purpose and characterises head office expenditure as executive and general administration expenses incurred outside India, including premises costs, personnel remuneration, travel and other prescribed items.

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