It is true that the arrastre charges constitute expenses of Yutivo and its non-inclusion in the selling price by Yutivo

cost the Government P4.00 per vehicle, but said non-inclusion was explained to have been due to an inadvertent
accounting omission, and could hardly be considered as proof of willful channelling and fraudulent evasion of sales
tax. Mere understatement of tax in itself does not prove fraud. (James Nicholson, 32 BTA 377, affirmed 90 F. (2) 978,
cited in Merten's Sec. 55.11 p. 21) The amount involved, moreover, is extremely small inducement for Yutivo to go
thru all the trouble of organizing SM. Besides, the non-inclusion of these small arrastre charges in the sales tax
returns of Yutivo is clearly shown in the records of Yutivo, which is uncharacteristic of fraud (See Insular Lumber Co.
vs. Collector, G.R. No. L-719, April 28, 1956.)