Before concluding that s. 32 of the Crown Liability and Proceedings Act (Canada) applied to statutory collection procedures under the Act as well as to Court procedures, Rothstein J.A. noted that to interpret s. 32 as applying only to court procedures would lead "to the perplexing conclusion that while court proceedings are subject to provincial limitation laws, the statutory collection procedures are not" and stated (at p. 5313):
"The Income Tax Act may contain incongruous provisions or provisions that appear to be inconsistent. However, where it is possible to construe legislation according to its words, so as to avoid incongruity or inconsistency, such construction is to be preferred."