The facts in this writ petition compel me to begin this judgment with some observations as regards the manner in which procedural provisions in a taxing statute ought to be interpreted in a developing economy such as ours. Although taxing statutes must receive a strict interpretation, designed as they are to exact money from a citizen so as to finance Government expenditure, the interpretation cannot be a reckless one, mindless of the probable impact that it could have on tax paying assessees or, as in the instant case, members of the trading community. To err is human, more so in accountancy, and unless it is established that the accounting lapse was the result of a willful omission or suppression with an intent to evade tax, the trade tax authorities in a civilized society should give due regard to the dignity of the members of the trading community and be more accommodative to reasonable requests for regularising technical omissions with a view to ensuring tax compliance. Ralph Waldo Emerson famously remarked that 'a foolish consistency is the hobgoblin of the mediocre mind'. In a similar vein, a mechanical application of procedural provisions in a Taxing Statute, with