Deduction for head office expenditure limited to a statutory ceiling or actual attributable expenditure for non-residents. Deduction is allowed for head office expenditure incurred outside India by a non-resident to the extent attributable to Indian business or profession, subject to the lower of a statutory ceiling based on the assessee's adjusted total income (or average adjusted total income if that income is a loss) and the actual attributable head office expenditure. Head office expenditure covers executive and general administration costs abroad, including rent, salaries for managing personnel, travel and related administrative items. Adjusted total income excludes the section 44C allowance and specified losses and deductions.