D E C I S I O N
GANCAYCO, J p:
The Commissioner of Customs, the herein petitioner, elevated this case on certiorari to this Court for a review of the decision of the respondent Court to Tax Appeals reversing the decision of the petitioner, holding that petitioner misapplied certain sections of the Tariff and Customs Code. 1 Earlier, petitioner affirmed the judgment rendered by his subordinate, the Collector of Customs of Manila.
The legal provisions involved in this case are Sections 1005, 2521, and 2523 of the Tariff and Customs Code. Section 1005 lays down the indispensable requirement that every vessel coming from a foreign part must have...
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