https://www.taxtmi.com/caselaws?id=783440 SC held that Section 44C of the Income-tax Act, 1961 applies to all "head office expenditure" of a non-resident, whether common or incurred exclusively for Indian branches, and that the statutory ceiling on deduction operates irrespective of such distinction. It rejected the interpretation that "exclusive expenditure" falls outside Section 44C and clarified that earlier decisions did not establish any binding principle excluding such expenditure. The term "head office expenditure" was construed as broad but confined to the categories specified or prescribed under the Explanation, without rendering clause (d) redundant. The question of law was answered in favour of Revenue, and the matters were remanded to ITAT, Mumbai, for limited factual verification. en-us Mon, 15 Dec 2025 00:00:00 +0530 Mon, 15 Dec 2025 17:54:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783440 SC held that Section 44C of the Income-tax Act, 1961 applies to all "head office expenditure" of a non-resident, whether common or incurred exclusively for Indian branches, and that the statutory ceiling on deduction operates irrespective of such distinction. It rejected the interpretation that "exclusive expenditure" falls outside Section 44C and clarified that earlier decisions did not establish any binding principle excluding such expenditure. The term "head office expenditure" was construed as broad but confined to the categories specified or prescribed under the Explanation, without rendering clause (d) redundant. The question of law was answered in favour of Revenue, and the matters were remanded to ITAT, Mumbai, for limited factual verification. Case-Laws Income Tax Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783440