Deduction for Head Office Expenditure limited to a statutory percentage of adjusted total income or actual attributable expenditure.

Section 44C allows non-residents a deduction for head office expenditure outside India attributable to Indian business or profession, limited to the lower of a prescribed percentage of adjusted total income (or of the average adjusted total income where adjusted total income is a loss) and the actual attributable head office expenditure. "Head office expenditure" means executive and general administration costs incurred outside India, including rent, employee remuneration, travel and related administration expenses. "Adjusted total income" excludes the section 44C allowance and specified carryforwards, depreciation and Chapter VI-A deductions.

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