Assessee is engaged in business of manufacturing pharmaceutical products. It had various manufacturing units and its Sikkim unit was eligible to claim deduction under section 80IE. It had also two research and development centres. It claimed deduction in respect of manufacturing unit at Sikkim under section 80IE.  Assessing Officer treated research and development expenditure to be inextricably linked with business of assessee including business relating to products that were manufactured in Sikkim unit for which deduction was claimed under section 80-IE and allocated said expenditure for computing deduction claimed under section 80-IE and partly disallowed deduction. CIT(A) deleted the disallowance. On appeal the Tribunal held that  since products developed in research and development centres were completely unrelated to products manufactured in Sikkim unit of assessee, allocation of research and development expenditure to Sikkim unit eligible for deduction under section 80-IE is  rightly deleted by Commissioner (Appeals). (AY. 2018-19, 2021-22)