M/S. KINFRA EXPORT PROMOTION INDUSTRIAL PARKS LTD., vs. THE JOINT COMMISSIONER OF INCOME TAX (OSD)
ITA/65/2018HC Kerala07 Apr 2022
Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI
Section 260A
224, para 22).
(Emphasis supplied)
"22. ... Ordinarily a proviso to a section is intended
to take out a part of the main section for special treatment.
It is not expected to enlarge the scope of the main section.
But cases have arisen in which this Court has held that
despite the fact that a provision is called a proviso