Held that the phrase “extension of existing business” came to be introduced in the statute on the basis of the Finance Bill, 2003 ((2003) 260 ITR (St.) 36). The words in the Explanatory Memorandum state the underlying objective of its insertion ((2003) 260 ITR (St.) 191, 207). The question whether the Tribunal erred in holding that installation of cell site towers amounted to “extension of existing business” as stipulated in the proviso to section 36(1)(iii) thereby warranting proportionate disallowance of interest under that provision had to be evaluated on an independent evaluation of the scheme of section 36(1)(iii) read along with the proviso and the legislative intendment underlying the insertion of that amendment in the Act. It would be imprudent and unwise to base the answer solely on the purported difference on the usage of word “extension” in section 36(1)(iii) as contrasted with “expansion” as appearing in other parts of the statute. Matter remanded to Assessing Officer to examine aspects pertaining to common pool of funds as framed by Tribunal and cell sites actually brought into use.(AY. 2019-20)