Overseas NRI Desk costs, including allocable staff,...

Overseas NRI Desk costs, including allocable staff, administrative, support, internal audit, financial control, IT, human resources, operations, rent, maintenance, depreciation and advertising expenses, fall within the Explanation to section 44C when incurred by a non-resident banking company. They are therefore treated as head office expenditure subject to the statutory limitation under section 44C, rather than direct business expenditure fully deductible under section 37(1). The disallowance of full deduction under section 37(1) was sustained, consistently with the settled treatment in earlier years and the cited Supreme Court authority.