Non-resident head office expenditure deduction remains capped by adjusted total income and average adjusted total income limits. Deduction is available to a non-resident for head office expenditure attributable to business or profession in India, subject to a statutory ceiling. The expenditure covered is executive and general administration expenditure incurred outside India, including premises costs, remuneration-related payments, travelling expenses, and other prescribed administrative matters. The deduction is limited to 5% of adjusted total income, or, where the adjusted total income is a loss, 5% of average adjusted total income, with adjusted total income computed without specified deductions, losses, and Chapter VIII deductions.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Non-resident head office expenditure deduction remains capped by adjusted total income and average adjusted total income limits.
Deduction is available to a non-resident for head office expenditure attributable to business or profession in India, subject to a statutory ceiling. The expenditure covered is executive and general administration expenditure incurred outside India, including premises costs, remuneration-related payments, travelling expenses, and other prescribed administrative matters. The deduction is limited to 5% of adjusted total income, or, where the adjusted total income is a loss, 5% of average adjusted total income, with adjusted total income computed without specified deductions, losses, and Chapter VIII deductions.
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