On appeal before the Tribunal, it was observed that the assessee has produced all the books and vouchers before the AO during the assessment proceedings. In fact, no show cause query was issued by the AO on this account. It was also observed that the units in the exempted zones were mainly engaged in manufacturing on job work where there was either negligible or no input cost of raw material involved. If the sales were made using its own raw material, there would be substantial difference in the gross profit rate in so far as if the cost of raw material was excluded, the gross profit in all the units would remain the same. The fact that the exempted unit had shown a loss had not been referred by the AO. Therefore, it was clear that no profit has been diverted to this unit. There had been no investigation or specific exercise to show that the amount claimed as deduction was wrong. Relying on the Delhi Tribunal decision in the case of Delhi Press Samachar Patra 103 TTJ (Del) 45 (supra)the Tribunal held that the disallowance of deduction u/s. 80-IC the by the AO could not be sustained. (ITA. No. 1194/Del/2015) (AY. 2011-12)