Assessee established an unit in State of Sikkim in an area notified by Central Board of Direct Taxes by Notification F. No. 142/35/2003-TPL, dated 6-2-2024 under section 80-IC(2)(a) for manufacture of pan masala (mouth freshener) not containing any tobacco or catechu. It claimed deduction under section 80IC(2)(a) Assessing Officer denied deduction on grounds that process applied by assessee did not amount to manufacture and product did not find mention in Fourteenth Schedule. Commissioner (Appeals) held that process applied by assessee amounted to manufacture and assessee was entitled for deduction. Tribunal held that process applied by assessee was manufacture but product shall stand excluded for deduction in view of Part B of Thirteenth Schedule to Act. Since part A of thirteenth schedule was applicable for State of Sikkim and legislature had not included pan masala in Part A of Thirteenth Schedule, pan masala without any tobacco content will not fall within purview of Entry 1 of Part A of Thirteenth Schedule and assessee is  entitled for deduction under section 80IC(2)(a)(i) read with section 80IC(3). (AY. 2007-08 to 2012-13)