Why a note could be in progress? (2,3,3)
I believe the answer is:
on the way
'in progress?' is the definition.
(I've seen this in another clue)
'why a note could be' is the wordplay.
'could be' indicates an anagram.
'why'+'a'+'note'='whyanote'
'whyanote' anagrammed gives 'ON THE WAY'.
(Other definitions for on the way that I've seen before include "In progress" , "About to arrive" , "In transit" , "En route" .)