A photon of energy h is absorbed by a free electron of a metal with...

According to Einstein's photoelectric equation, the maximum kinetic energy of an emitted photoelectron is given by K_\max = h\nu - \phi.

This maximum kinetic energy corresponds to the electrons emitted from the surface without suffering any collisions.

However, when a photon is absorbed by an electron deeper inside the metal, the electron may suffer collisions with other atoms or electrons before reaching the surface, thereby losing a part of its energy.

As a result, the kinetic energy of the emitted electron can be any value ranging from $0$ to $h\nu - \phi$. It is also possible that the electron loses so much energy that it does not emerge at all.

Therefore, the electron may emerge with a kinetic energy less than $h\nu - \phi$.