Payment under compulsion is not voluntary; it does not waive the right to litigate or the need for a reasoned order.
Payment under protest or commercial compulsion does not amount to voluntary acceptance of liability or waiver of the right to litigate; it only bars coercive action. The proper officer remains obliged to adjudicate a show cause notice by considering objections and passing a final, reasoned speaking order justifying any tax or penalty demand. Failure to provide reasons violates principles of natural justice and undermines appellate and judicial review, and written replies prevail over contradictory oral submissions. (AI Summary)