Indian Supreme Court Holds Section 44C Cap Applies to Head Office Expenditure Even if Incurred Exclusively for Indian Branches

In a decision dated 15 December 2025, the Supreme Court of India considered whether Section 44C (deduction of head office expenditure for non-residents) applies only to “common” head office expenses or also to expenses incurred by the head office exclusively for Indian branches/operations.
The Court held that Section 44C applies to “head office expenditure” regardless of whether it is common e…
Continue Reading