As seen from the record, the authorities have concurrently held that the assessee has forayed into an entirely new business, and so whatever investment it has made must amount to capital investment. Eventually, the authorities have held, applying the proviso to section 36 (1) (iii), that the assessee borrowed capital to acquire an asset (a licence to broadcast) and that the business had not commenced. Tribunal, while concurring with the primary and appellate authorities, has observed that to claim the benefit of expenditure, it must concern business carried on by the assessee, and the profits to be computed and assessed to tax should be earned after the business is set up. It has concluded on facts that, by the time the assessee claimed the tax benefit, it had not set up the business or made it operational; so the question of interest concession under section 36 (1) (iii) of the Act does not arise. 43. Indisputably, the assessee could not demonstrate to AO’s satisfaction that it actually invested its own funds rather than those it borrowed. Thus, we find it difficult to upset the concurrent findings. Indeed, the assessee did enter a new line of business, unconnected to its existing business, and it had not by then commenced that new business. 44. So, we uphold the Tribunal’s findings on the AO’s disallowing Rs. 83.21 lac towards interest on investment expenditure the assessee incurred on its new the line of business. 45. To sum up, we answer the substantial questions of law one and two in assessee’s favour; three and four in the Revenue’s favour. Thus, the appeal is partly allowed. No order on costs.