In the case of Dharandas Tulsidas et al. v. Insular Collector of Customs in 1922, the Supreme Court ruled on a dispute involving import duties and taxes imposed by Philippine customs authorities on goods imported from India by an Indian merchant named Dharandas Tulsidas. The court held that under the Tariff Act of 1909, which was applicable at that time in Philippines (then a U.S territory), goods originating from countries like India were subject to specific rates of duty as prescribed under Section 21(a) irrespective of any preferential treatment provided for British colonies or possessions under Section 2. Therefore, it upheld the decision made by lower courts and dismissed Tulsidas's claim for refunding excess charges levied upon his imports.

In the dissenting opinion for Dharandas Tulsidas et al. v. Insular Collector of Customs, it was argued that the majority's interpretation of the law was incorrect and unjustly penalized innocent parties. The dissenting justices believed that while there may have been a technical violation of customs regulations due to an error in paperwork, this should not result in forfeiture of goods as if they were contraband. They contended that such harsh penalties should be reserved for those who deliberately attempt to defraud or evade duties, not those who make honest mistakes or oversights in their documentation process. Furthermore, they disagreed with the majority's view on burden proof; arguing instead that once innocence is shown by preponderance evidence then guilt must be proven beyond reasonable doubt before punishment can be imposed.