The Supreme Court has held that the ceiling limit prescribed under Section 44C of the Income Tax Act, 1961, applies to “head office expenditure” incurred by a non-resident assessee, regardless of whether such expenditure is “common” to multiple branches or incurred “exclusively” for the Indian branch. A Bench comprising Justice J.B. Pardiwala and Justice K.V.
Section 44C Ceiling Applies to Both Common and Exclusive Head Office Expenditure of Non-Resident Assessees: Supreme Court
