Section 111, The Goods and Services Tax Act, 2009

(1) In interpreting a provision of this Act, a constructionthat would promote the purpose or object underlying the provision of the Act (whether that purpose or object is expressly stated in the Act or not) should be preferred to a construction that would not promote that purpose or object. (2) Subject to subsection (5), in interpreting a provision of this Act, if any material that does not form part of the Act is capable of assisting in ascertaining the meaning of the provision, consideration may be given to that material– (a) to confirm that the meaning of the provision is the ordinary meaning conveyed by the text of the provision, taking into account its context in the Act and the purpose or object underlying the Act; or (b) to determine the meaning of the provision when– (i) the provision is ambiguous or obscure; (ii) the ordinary meaning conveyed by the text and taking into account its context in the Act and the purpose or object underlying the Act leads to a result that is manifestly absurd or is unreasonable. (3) Without limiting the generality of subsection (2), the material that may be considered in interpreting a provision of this Act includes– (a) all matters not forming part of the Act that are set out in the document containing the text of the Act; (b) any treaty or other international agreement or international assistance agreement that is referred to in the Act; (c) any explanatory memorandum relating to the Bill containing the provision or any other relevant document, that was laid before or furnished to the members of Parliament by a Minister before the Bill was enacted; (d) the speech made to Parliament by a Minister on the occasion of the moving by that Minister of a motion that the Bill containing the provision be read a second time; (e) any document (whether or not a document to which a preceding paragraph applies) that is declared by the Act to be a relevant document for the purposes of this section; (f) any relevant material in any official record of proceedings of debates in the Parliament. (5) In determining whether consideration should be given to any material in accordance with subsection (3) or in considering the weight to be given to the material, regard should be had, in addition to any other relevant matters, to– (a) the desirability of persons being able to rely on the ordinary meaning conveyed by the text of the provision taking into account its context in the Act and the purpose or object underlying the Act; and 112 113 Purposive interpretation ot Act. (b) the need to avoid prolonging legal or other proceedings without compensating advantage.