MUKHTAR, J.S.C. (Delivering the Leading Judgment): In the Mobile Revenue Court of Edo State sitting at Benin City, the following charge was framed against the appellant:
"Count 1: That Unipetrol Plc., Benin City, between January, 1993 to December, 1995 at Benin City within the jurisdiction of the Edo State Mobile Revenue Court, without lawful justification or excuse, failed to pay the sum of One million, two hundred and sixty two thousand, five hundred and seven Naira (₦1,262,507.00) being outstanding PAYE Tax liabilities for the said period and thereby committed an offence contrary to section 51(2)(b) of the Income Tax Law, Cap. 71, Vol. III, Laws of Bendel State now applicable to Edo State.
Count II: That Unipetrol Plc., Benin City, between January, 1993 to December, 1995 at Benin City within the jurisdiction of the Edo State Mobile Revenue Court, without lawful justification or excuse, failed to pay the sum of Two hundred and forty-four thousand, one hundred and thirty-one Naira (₦…