2. The costs of lawsuit shall be borne by the Plaintiff.

A. The Plaintiff from January 21, 2013 to the same year

7. 25.까지 중화인민공화국 소재 엡손 이엔지알 선진(EPSON ENGR SHENZHEN LTD.)으로부터 원산지가 중화인민공화국인 LCD 프로젝터(이하 ‘이 사건 프로젝터’라 한다)를 별지와 같이 총 32회에 걸쳐 수입하면서, 이 사건 프로젝터를 관세율표 품목번호(이하 ‘품목번호’라 한다) 제8528.69호에서 정한 ‘기타 프로젝터’로 분류하여 수입물품 가격에 기본관세율 8%를 적용하여 계산한 관세 및 부가가치세 합계 2,303,317,360원을 신고납부하였다.

B. On January 13, 2015, the Plaintiff filed a claim for correction against the sum of KRW 2,303,317,360 on the grounds that the instant projector constituted an “pro projector” under Article 8528.61 of the Item No. 8528, which is 0% of the tariff rate, for correction of KRW 2,303,317,360 on the grounds that the said duty and value-added tax was a product exclusively or mainly used for the automatic data processing system. However, on January 23, 2015, the Defendant rejected the instant claim for correction on the ground that the product number corresponding to the pro projector was 8528.69

(hereinafter “instant disposition”). C.

On April 22, 2015, the Plaintiff filed an appeal with the Tax Tribunal on April 22, 2015, but was dismissed on June 12, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 and 2 (including virtual number), the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion 1) The projector of this case is a projector mainly used in the automatic data processing system set forth in No. 8471 for the following reasons and falls under the item number No. 8528.61. ① The primary use of the projector of this case is connected to a computer, which is an automatic data processing system, and it is confirmed by the usage of the same kind of goods currently being used in Korea. ② The interpretation of the Tariff Schedules can be classified according to subparagraph 3(a) or (b) of the General Rule on the Interpretation of Tariff Schedules.