Deduction of head office expenditure in the case of non-residents

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....hall be made, in computing the income chargeable under the head "Profits and gains of business or profession", in respect of so much of the expenditure in the nature of head office expenditure as is in excess of the amount computed as hereunder, namely:- (a) an amount equal to five per cent of the adjusted total income; or (b) ^2[****] (c) the amount of so much of the ex....

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....on 36 or any loss carried forward under sub-section (1) of section 72 or sub-section (2) of section 73 or ^3[sub-section (1) or sub-section (3) of section 74] or sub-section (3) of section 74A or the deductions under Chapter VI-A; (ii) "average adjusted total income" means,- (a) in a case where the total income of the assessee is assessable for each of the three assessment years ....

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....dministration expenditure incurred by the assessee outside India, including expenditure incurred in respect of- (a) rent, rates, taxes, repairs or insurance of any premises outside India used for the purposes of the business or profession; (b) salary, wages, annuity, pension, fees, bonus, commission, gratuity, perquisites or profits in lieu of or in addition to salary, whether pa....

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.... read as, "sub-section (1) of section 74" 4.  Omitted vide Section 11 of the Finance Act, 1993 w.e.f. 01-04-1993 before it was read as,  "(iii) "average head office expenditure" means, - (a) in a case where any expenditure in the nature of head office expenditure has been allowed as a deduction in computing the income of the assessee chargeable under the....