D E C I S I O N
FERNANDO, J:
It is a novel question that this petition for the review of a decision of respondent Court of Tax Appeals presents. Petitioner Republic Flour Mills, Inc. would have this Court construe the words "products of the Philippines" found in Section 2802 of the Tariff and Customs Code 1 as excluding bran (ipa) and pollard (darak) on the ground that, coming as they do from wheat grain which is imported in the Philippines, they are merely waste and not the product, which is the flour produced. 2 That way, it would not be liable at all for the wharfage dues assessed under such section by respondent...
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