Assessee company was carrying on business of manufacture and export of pharmaceuticals.  Tribunal allocated R & D expenditure to a unit of assessee.  Assessee contended that Tribunal was not justified in allocating research and development expenditure to said unit as no product were manufactured in said unit during year. How court held that  from perusal of record, it was evident that two products were manufactured by said unit in preceding year for which research and development was done by other units of assessee,  no product was manufactured by it relevant year. Therefore, there could not be apportionment of current year’s expenditure of assesse to said unit. Court also held that if incurred capital expenditure towards research and development R &  said  expenditure was to be excluded from toil capital expenditure while allowing expenditure on R & D units.  (AY.  2001-02)