A proviso which is inserted to remedy unintended consequences and to make the provision workable , a proviso which supplies an obvious omission in the section , is required to be read in to section to give the section a reasonable interpretation and requires to be treated as retrospective in operation so that a reasonable interpretation can be given to the section as a whole .
CIT v. Calcutta Export Company (2018) 404 ITR 654/ 165 DTR 321/302 CTR 201/ 255 Taxman 293 (SC), www.itatonline.org
Interpretation of taxing statues- Proviso- Amendment to remedy unintended consequences and make provision workable is to be treated as retrospective .[ S.40(a)(ia) ,139(1)]