Allowing  the appeal of the assessee the Tribunal held that; there must be direct nexus between profits and gains of industrial undertaking and expenses which were sought to be apportioned/attributable to it. Neither AO nor CIT(A) had examined nature of expenses and its nexus between STP unit or non-STP unit. Under these set of facts, issue required fresh examination at end of AO  Referred Zandu Pharmaceutical Works Ltd  (ITA No 8 of 2007 dt 12-09-2012) (AY. 2004 -05, 2005 -06)