From: The Income-tax Act, 1961
44C. Deduction of head office expenditure in the case of non -residents .-Notwithstanding anything to the contrary contained in sections 28 to 43A, in the case of an assessee, being a non-resident, no allowance shall 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 compu ted as hereunder, namely: -