No action or proceeding shall be maintained in any court for the purpose of restraining or delaying the collection or payment of a statement rendered in accordance with the provisions of this article. A corporation against which a statement is rendered shall pay the amount thereof, and after the payment may in the manner provided by this article at any time within two years from the date of the payment, bring against the state an action at law to recover the amount paid, with legal interest thereon from the date of payment, upon the ground that the assessment was excessive, erroneous, unlawful or invalid in whole or in part.