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Commercial and Taxation Laws
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Question
A company pays an order of payment that, on the stipulated facts, lacks the factual and legal basis necessary to constitute a valid assessment. It later files a proper Section 196 refund claim and timely sues within the governing two-year period. The city insists that every payment order necessarily triggered Section 195 and that no refund is possible without a protest within sixty days. Which response follows Tigerway?