Voluntary payment of tax demanded under an unchallenged...

Voluntary payment of tax demanded under an unchallenged show-cause notice alleging fraudulent transactions amounts to acquiescence in the notice and admission of its allegations. Once tax is paid without objection to the invocation of section 74, no separate finding of fraud is required for consequential interest and penalty. Payment does not permit the taxpayer to later deny that liability, and the procedure does not breach section 74(5). The interest and penalty demand therefore remains enforceable.