This is an appeal taken by the Collector of Internal  Revenue from a decision of the Court of Tax Appeals holding that the Manila Lodge No. 761 of the Benevolent & Protective Order of Elks "is not liable for privilege taxes on its sale by retail of liquor and tobacco exclusively to its members and  their guests," and reversing and  setting aside a decision of said appellant to the contrary, dated November 19, 1953,  without special pronouncement as to costs. The uncontested facts are set forth in the  decision of said  Court, from  which we quote:

"This is an appeal from two decisions of the respondent Collector of Internal Revenue assessing and  demanding from  the petitioner herein the  sums of P1,203.50 and P332.00, respectively representing fixed taxes as retail  dealer  in liquor, fermented liquor, and tobacco, allegedly due from petitioner for the period from the 4th  quarter of 1946 to  1953 and the period from 1954-1955pursuant to subsections  (i),  (k) and  (n) of section 193 of" the Tax Code, in relation to 178 of the same Code.

"The petitioner,  Manila Lodge No. 761 is  admittedly a fraternal, civic,  non-stock, non-profit  organization duly  incorporated  under Philippine laws.  It owns and operates a clubhouse located at Dewey Boulevard, Manila,  wherein it sells at retail, liquor, fermented liquor, cigar and cigarettes only to its members and their guests.  B.I.R. agents discovered that the  Manila Elks Club had not paid  for the period in question  the privilege tax for retail liquor dealer (B-4), retail  dealer  in fermented  liquor (B-7), and  retail tobacco dealer (B-9-a) prescribed in section 193 of the Tax Code.

"On November 19,  1953, the Collector of Internal Revenue assessed against and demanded  from the petitioner the payment of the  sum of P1,203.50 representing  fixed taxes, as retail dealer,  for the period from its 4th quarter of 1946 to 1953, exclusive of the suggested compromise penalty of  P80.00.  The petitioner,  claiming that it  was exempted from the payment of the privilege taxes in question, requested that the said assessment be reviewed by the Conference Staff of the Bureau of Internal Revenue.  The Conference Staff, after due hearing, upheld and reiterated the assessment made by the respondent Collector of Internal Revenue.  Forthwith, the petitioner appealed to this Court on June 1, 1955.

"During  the pendency of the original petition for  review in  the above-entitled case, respondent  issued another assessment covering fixed taxes for the years 1954 to 1955 in the  amount  of  P332.00, exclusive of the  suggested compromise penalty of  P50.00.  Consequently,  petitioner with leave of Court filed a  supplemental  petition for review which  included the latter assessment.

"Petitioner  bases its claim  for  exemption  from the  payment  of the privilege taxes' in question on  the  grounds that it is not  engaged ,in  the  business of selling at  retail  liquor,  fermented  liquor, and tobacco because the sale  of these aforementioned specific  goods  is made only to members of the club and their guests' on a very limited scale in  pursuance only of its general purpose as a  fraternal social club, to provide comfort, recreation, and convenience to such members, and merely to provide enough margin  to cover operational expenses.' (Petitioner's Memo p. 3).

"Respondent, on the other  hand, maintains that  persons selling articles subject  to specific tax, such  as cigars,  tobacco liquor and the like, are subject to the fixed taxes imposed by section 193 of the Tax Code, irrespective of whether or not they made  profit,  and whether  or not they are civic or fraternal  dubs selling only to their members and their guests.  This contention is  based on a  ruling  promulgated by the Bureau of Internal Revenue made in 1921."

Petitioner herein maintains that:

"1. The  respondent Court of  Tax Appeals erred in reversing the decision  of the petitioner-appellant which  held  the respondent  club liable for fixed taxes.

"2.  The respondent Court of Tax Appeals  erred in  holding that before respondent  club's liability for the privilege taxes  imposed by section  193 of the Tax  Code  attaches it is  necessary  that it be engaged in the 'business' of selling liquor and tobacco.

 "3. The respondent Court of Tax Appeals erred in  holding that a fraternal, civic, non-stock,  non-profit organization like  the  respondent club selling at retail liquor  and tobacco only to its members  and their  guests with  just  enough  margin to cover operational expenses should not be  held liable for the fixed taxes incident  to the business of selling at retail, liquor and  tobacco.

"4.  The respondent Court of Tax Appeals  erred in holding that the administrative construction of  the Bureau of Internal  Revenue on the matter  in question  is outside the ambit of, and is inconsistent with, the Revised  Administrative  Code and Tax Code."

This  appeal is untenable.  In the language  of the Court of  Tax  Appeals:

"The bone of contention between the two parties herein * * *, lies in the proper  interpretation and application of  the pertinent provisions of the Tax Code, namely,  subsections  (i), (k)  and  (n)  of section  193 in relation to section 178 of the Tax Code, which we quote hereunder:

'SEC.  178. Payment  of privilege taxes. A privilege tax must be paid before any  business or occupation hereinafter specified  can be lawfully begun  or pursued.  The tax  on business  is  payable for every separate or distinct establishment or place where  the business subject  to the tax is conducted; and one occupation or line of business does not become exempt by being  conducted with some other occupation or  business for which  such tax has been paid.

'The occupation tax must be paid by each individual engaged in a calling  subject thereto; the tax on a business by the person,  firm, or company  conducting the same.'  (Italics supplied.)

SEC. 193. Amount of tax on business. Fixed  taxes  on business shall be collected as follows, the amount stated being for the whole year when not otherwise specified:
(i) Retail liquor dealers, one hundred pesos.
(k) Retail dealers  in fermented liquors, fifty pesos.

          *      *      *      *      *      *

(n) Wholesale tobacco dealers,  sixty pesos;  retail tobacco dealers, sixteen  pesos/

"The  aforequoted provisions of the Tax Code are clear and precise. The privilege taxes prescribed  in section 193  of  the Tax Code in relation  to  section 178 of the same,  are to be  imposed only on persons  or entities who engage in the activities mentioned or classified therein  for 'business'  purposes.   This evident intention of the law becomes more palpable when we take  into  consideration the fact that the drafters of  our  Tax  Code  had grouped  the  aforequoted provisions of law under one general division of the Tax Code  headed as 'Title V, Privilege  Taxes on Business and occupation.'

"It is not therefore  entirely correct to maintain as respondent does, that all  persons selling articles subject  to specific taxes, like liquor and  tobacco, should likewise be subject to the fixed  taxes imposed by section 193 of the Tax Code.  We believe, that in order that these persons  should  be subjected  to  the privilege taxes imposed by the aforementioned section of the Tax Code, it  is  necessary  that they be engaged  in  the 'business' of  selling liquor and tobacco, otherwise the privilege taxes as a dealer of liquor and tobacco can not attach.

"At this juncture a definition of the word  'business' is in order and we have the following:

'The word 'business' in its ordinary and common use  is employed to designate human efforts which have for their and living or reward; it is not commonly used as descriptive  of charitable, religious, educational  or social agencies.'  (Ballantine's Law Dictionary,  1948 Ed. P. 179)

 'Business 'that which busies or engages time, attention or labor as a principal serious concern or interest; any particular occupation or employment habitually engaged in specially for livelihood or gain/ (Vol. 1, 1949 Merriam-Webster's New International  Dictionary, 2nd Ed. p. 362.).

"Other definitions of the term 'business' as given  by judicial  pronouncement are found in Volume V,  Words  and Phrases,  page 999 as follows:

 'Business is a word of large signification, and denotes the employment or occupation in which a person  is engaged to procure a living'. (Citing: Goddard v. Chaffee, 84 Mass  (Allen) 395; 79 Am Dec. 796). 'Business in common speech means  habitual or regular occupation that a party is engaged in with a view to winning a  livelihood or some gain,'  (Citing: In re Lemont, 41 p. 2D, 497, 502)

'An  enterprise not; conducted as a means of livelihood or  for profit does not come within the ordinary meaning of the terms,  'business, trade or industry.'  (Citing City of  Rochester vs. Rochester Girl's Home, 194 N.Y.S. 236, 237).

'The  term 'business' as used in  law  imposing a license  tax on business, trades, etc. ordinarily  means business in  the  trade or commercial sense only, carried on with a view to profit or livelihood.' (Citing: Cuzner vs. California Club 100 p.  868, 867, 155,  Cal.  303, 20 L.R.A. N.S. 1095).

"From the foregoing  definitions,  it is evident that the  plain, ordinary meaning of 'business'  is restricted  to  activities or  affairs where  profit is the  purpose, or livelihood is  the motive.   The term 'business' being used without any qualification in section 193  of the Tax Code in relation to section  178 of the same, should therefore be construed in its plain and ordinary meaning, restricted to  activities for profit or livelihood.

"With these  considerations in mind, we now come to the question of whether or not the Manila Elks Club  is engaged in the  'business' of selling liquor and tobacco.

''Respondent, in paragraph 1 of his answer, admits that the petitioner  herein,  Manila Elks Club  is  a  fraternal, civic,  non-stock, non-profit organization,  fit has been  established without contradiction that the Manila Elks  Club, in pursuance of its purpose as  a fraternal social club, sells on retail at its clubhouse on Dewey  Boulevard, liquor, cigars and cigarettes, on a very limited scale, only to its members and their  guests, providing just enough margin to cover operational expenses without intention to obtain profit.  Such being the case then, the  Manila  Elks Club cannot be considered  as engaged  in the 'business'  of  selling liquor and tobacco.

'Where the corporation handled  no money except such as was necessary to cover operational expenses,  conducted  no business for itself,  and engaged in no transactions that contemplated a  profit for itself such  a corporation is considered not organized for  profit under  the General  Corporation Law.'   (Read v.  Tidewater  Goal Exch. 116 A 898, 904, cited in  Vol. 34,  Words &  Phrases, p. 220, defining  'profits'; underscoring provided.)

"The petitioner herein, Manila Elks Club, not being engaged in the business  of selling at  retail liquor  and tobacco, cannot therefore be held liable for the privilege taxes required by section 193, subsections (1), (k) and (n). The weight of American authorities  enhances the strength of  our findings that a fraternal, civic, non-stock, nonprofit organization, like the Elks Club, selling at retail liquor and tobacco only to its members and their guests in pursuance with its general purpose as a fraternal  social dub with just enough margin to  cover  operational  expenses,  should not  be held liable  for  the fixed taxes incident to the business of selling at retail, liquor and tobacco.

'A bonafide social club, which  disposes  of liquors  at its clubhouse to members and their guests at a  fixed  charge as incident to the general purposes of the organizational is not required to take out a license by Rev. Laws No. 3777-3785,  approved March 15,  1905, which provides for a license upon the business of disposing intoxicating liquors; the term  business in such statute meaning  business in the trade or commercial sense.   (State v.  University Club, 130 p. 468, 470; 35 Nev. 475; 44 L.R.A., N. S. 1026).

A social club, not organized for the purpose of evading the liquor laws, but which furnishes its members with liquors and refreshments without  profit to  itself,  is not  a  retail liquor dealer,  within  the statute imposing a license tax on all  persons dealing in, selling or disposing of intoxicating liquors by  retail.'  (Barden v. Montan Club, 25 P. 1042, 10 Mont. 330, II L.R.A. 693).

'Acts 1881, C. 149,  authorizing taxation of liquors  dealers, does not  include  a social  club  maintaining  a  library, giving musical entertainments, and furnishing  meals  for its members,  which keeps a small  stock of liquor; the members paying for its  drink as it is taken,  but no profit being made  on such sales.'  (Tennessee Club of Memphis v. Dwyer, 79 Tenn.  (11 Lea) 452, 461, 47 Am. Rep. 298.) 'A social club composed  of  members  who  have no  proprietary interest in the assets which provides a reading room, restaurant, bar room, library, billiard  rooms and sitting  rooms for  its members, the expenses of which  are defrayed  by annual dues from each member, and by payments  made by the members for food and drinks, is not engaged  in the business of a retail liquor dealer, within section 11 of the Louisiana License Tax Laws.'  (La Ann. 585, 20 L.R.A. 185).

Respondent, however, insists that the petitioner should pay the privilege tax on the sale at retail of liquor and tobacco because this has been allegedly the practice consistently  followed by  the Bureau  of Internal Revenue since 1921, and because section  1464 of the Revised Administrative  Code under which said  ruling was then based had been reenacted by the legislature  as section  193 of the  National Internal Revenue Code.  Thus, respondent contends,  that the policy of the Bureau of Internal Revenue has therefore  gained 'approval by legislative reenactments.'

"The alleged administrative practice is founded upon the  following ruling rendered in 1921.

'Clubs  selling exclusively to members thereof  liquors and  other products on which the specific tax  is imposed should pay  the privilege tax corresponding to the business  engaged in.  The  fact that such products are sold at cost to the members of the club does not affect the club's liability to tax.'  (Ruling, Oct. 13,1921, B.I.R. 105.02; Exh. 3, pp. 66-69. BIR records.)

"We do not agree with  the contention of the  respondent.  While there is admittedly a ruling on this point in 1921,  there is  no showing that such has been a long-continued practice. Be  that as it may, any such administrative  construction  must be within the ambit of, and must be consistent with,  the Revised Administrative Code and the Tax Code.   It  is likewise the  rule that where  the  statute is unambiguous, an administrative construction is unwarranted (U. S. vs. Missouri P. R. Co. 278 U. S. 269,  73 L. Ed. 322) and  no construction may be made to restrict or enlarge the  meaning of  an Act.  (Blatt vs. U. S., 305 U. S. 267,  83 L. Ed.  167).

"An  examination of section  1464 of  the  Revised  Administrative Code taken in connection with section 1453 of the same, discloses the fact that aside from the  change in  rates of taxes to be paid and the arrangement of the  classification of businesses enumerated therein, section 193 of the present Tax Code is a verbatim copy of the aforementioned  provisions  of  the  Revised  Administrative   Code.  The policy or principle  followed  by the said code regarding privileges taxes, i.e. that the privilege taxes are payable  only by those persons or entities engaged in the business enumerated  in section 1464 of the said Code, has not suffered any change, and the same still obtains under our present Tax Code.  In the absence of  a showing that the legislative body had  been apprised of  the  aforesaid ruling,  what has gained  legislative approval  thru reenactment  is,  we believe, the policy behind the above-mentioned provision of the Revised Administrative Code of taxing persons engaged in business and not the alleged practice following the  administrative ruling of 1921.  We believe that no amount  of trenchant adherence to  an  established practice may justify its continued application where  it is clear and manifest that the same is not in consonance with the policy of the legislature as defined by law."

It is urged by appellant that emphasis should be placed not on  the term "business",  but on  the phrases "retail liquor dealers", "retail dealers in fermented liquors" and "retail tobacco  dealers",  appearing  in  section 193 of  the National Internal Revenue Code,  which are defined in section 194 thereof as follows:

"Sec. 194. Words and phrase defined. In applying the provisions of the preceding section, words and phrases  shall be taken in the sense and extension indicated below:

*         *       *     *      *      *      *

"(i) 'Retail liquor dealer' includes  every person, except a  retail vino dealer, who for himself or on commission sells or offers for sale wine or distilled spirits (other than denatured alcohol) in quantities of five liters or less at any one time and not for resale.

*         *      *       *       *        *       *

"(k) 'Retail  dealer in fermented liquors'  includes every person, except retail dealers in tuba, basi, and tapuy, who for himself or on commission sells or offers for sale fermented liquors and quantities of five liters or less at any one time and not for resale.

*         *       *       *       *        *        *

"(o) 'Tobacco dealer'  comprehends every person who for himself or on commission sells  or  offers  for sale cigars,  cigarettes,  or manufactured tobacco."

Undoubtedly,  these  definitions must  be given all  the weight due thereto, in the interpretation of section 193 of the Tax Code.  As used therein, the phrases above referred to are, however, part and parcel of the provisions contained, not  only in said section 193, but, also, in  section 178 and other parts of the 'Tax Code, all of which must  be  given effect in their entirety as a harmonious, coordinated and integrated unit, not as a mass of heterogeneous and unrelated  if not  incongruous terms,  clauses and sentences.   In other words, the phrases in question should be construed in the light of the context of the whole Tax Code, of which they are integral parts.  And when this is done when we consider that  section 193 requires  "retail liquor  dealers", "retail  dealers in fermented liquors" and "retail tobacco Collector of Internal Revenue vs. Manila Lodge No. 761 of the Benevolent & Protective Order of Elks and the  CTA dealers" to pay the taxes on business" therein specified; that said section 193 is entitled "Amount of tax on  business"; that said section 193 merely implements the general provision in section 178, to the effect that "a privilege tax must be paid before any business or occupation hereinafter specified  can be lawfully begun and pursued";  that the term "business" is used in said  section 178 six (6) times; and that the aforementioned sections 178% 193 and 194 are part of Title V of the Tax  Code, entitled "Privilege taxes on business and occupation" it becomes crystal clear that the "retail liquor dealers",  "retail dealers in fermented liquors" and "retail tobacco dealers" alluded to in said section 193  are  those engaged in "business",  not fraternal, civic, non-stock, non-profit organizations, like herein respondent,  which sells  wines, distilled  spirits, fermented liquors  and tobacco, exclusively to  its members and their guests,  at such  prices as are merely  sufficient to cover operational expenses.

Petitioner assails the applicability of the decisions relied upon by the  Court of Tax Appeals, upon the ground that said decisions refer to  the authority to license, and, hence, to the exercise of the police power, not that of  taxation which  is involved in the case at bar.  However, the distinction made  enhances instead of detracting from the weight of said decisions as precedents, insofar as the issue herein is concerned.  Indeed, the police power is, in general broader and subject to less restrictions than the power to tax.   It is not difficult to  conceive  the advisability, if not, necessity, of requiring  a license for some activities under- taken by so-called "clubs", owing to the possibility, if not probability, of  use of said name, appellation or denomination, in order to avoid or evade some laws or to camouflage certain  ventures, pursuits or enterprises which otherwise would  clearly  be illegal,  immoral  or contrary to public policy.  Upon  the other hand, a tax is  a burden and,  as such, it will not be deemed  imposed upon fraternal, civic, non-profit, non-stock organizations, unless the intent to the contrary is manifest and patent.

Wherefore, the appealed decision  of the Court of Tax Appeals is hereby affirmed, without special pronouncement as to costs.  It is so ordered.

Paras,  C. J.,  Bengzon,  Padilla,  Montemayor, Bautista Angelo, Endencia and Barrera, JJ., concur.