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

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....red by such assessee as is attributable to his business or profession in India, shall be allowed in computing the income chargeable under the head "Profits and gains of business or profession" subject to provisions of sub-section (2). (2) The deduction allowable under sub-section (1) shall be restricted to- (a) if the adjusted total income of the assessee is a loss, to an upper monetary limit o....

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....the said three tax years, the arithmetic mean of his adjusted total income over those two tax years; (iii) if the assessee is assessable only for one of the said three tax years, his adjusted total income for that tax year; (c) "head office expenditure" means executive and general administration expenditure incurred by the assessee outside India, including expenditure incurred in respect of- ....