UOI reported in 1997 (89) E.L.T. - 247 (S.C.) has observed
that - "when a person proposes to contest his liability by
way of appeal, revision or in the higher courts, he would
naturally pay the duty, whenever he does, under protest".
Relying on these observations of Hon'ble Supreme Court,
the Tribunal in the cases of CC (Prev.), Jamnagar v.
Continental Petroleums Ltd., reported in 2009 (234) E.L.T.
333 (Tri.-Ahmd.)