Tribunal held that  Section 35D provides for amortisation of capital expenditure relating to specified items which have been incurred “before the commencement of business” or “after the commencement of his business, in connection with the extension of its undertaking or in connection with his setting up a new industrial unit” provided in sub-section (2)(i) and (ii) of section 35D respectively. The purpose of the assessee’s capital raised was investment in capital equipment, working capital requirement, general corporate purposes and issue expenses. The assessee’s case fell under section 35D(2)(ii) since the expenditure was in connection with the extension of its undertaking. The findings of the Commissioner (Appeals) deleting the section 35D disallowance of Rs. 120 crores in both these assessment years were to be upheld. ( AY.2010-11, 2011-12)