Head office expenditure limits for non residents cap deductions to the least available statutory measure. Section 44C limits deduction of head office expenditure for non-residents to the least of: five per cent of the adjusted total income, the (omitted) alternative, or the amount attributable to the assessee's Indian business. If adjusted total income is a loss, the five percent is computed on the average adjusted total income across up to three prior years. 'Adjusted total income' excludes the allowance under this section and certain capital allowances, specified deductions, carried forward losses and Chapter VI A deductions. 'Head office expenditure' comprises executive and general administration costs incurred outside India, including premises costs, remuneration of foreign office personnel, travel, and prescribed related items.