The assessee had three units and one unit manufacturing heaters was not eligible for deduction and  the  said unit supplied those heaters to other two eligible units engaged in production of refills at a particular excisable value. AO disallowed deduction claimed under section 80-IB in respect of Units 2 and 3 which related to supply of heaters from non-eligible Unit 1.  CIT(A)  up held the order of AO. Tribunal held that in absence of any other rational basis for allocating income for computation of amount eligible for deduction, ratio of excisable value of output of non-eligible unit vis-a-vis that of eligible units would constitute a good basis for bifurcation of income. Matter remanded.