A. On November 16, 2005, the Busan Metropolitan City Mayor designated Busan Cririwon as D industrial complex on November 16, 2005 and designated the Defendant and Busan City Corporation as the project implementer when approving the development plan.

B. On February 28, 2006, the Plaintiff filed an application for replotting for 429,325 square meters of land owned by the Plaintiff in the D Industrial Complex, Busan E, and 40 square meters of land owned by the Plaintiff.

On October 31, 2008, the Mayor of Busan Metropolitan City approved the alteration of designation (development plan) and implementation plan of D industrial complex including the contents of incorporating the above FF forest 496 square meters into the above industrial complex, and on October 6, 2010, approved D industrial complex plan (revision) including the contents of changing the owner of the above F forest 496 square meters from the Sung Chang Enterprise Co., Ltd. to the plaintiff.

On January 21, 2011, the Defendant: (a) replaced the Plaintiff with the land of 432,605 square meters, including the said F Forest, with the land of 66,116 square meters for Busan G G G factory site (hereinafter “instant land”); and (b) notified the Plaintiff of a replotting disposition plan with the purport of determining the liquidation amount of the replotting disposition as KRW 969,409,504; and (c) on January 26, 2011, publicly announced the disposition of land substitution for D industrial complex development projects in accordance with the said plan

C. The Plaintiff acquired the instant land through the said replotting disposition, and was exempted from property tax and local education tax from 2011 to 2013 pursuant to Article 78(4) of the former Restriction of Special Local Taxation Act (amended by Act No. 11138, Dec. 31, 201; hereinafter the same).

On December 8, 2014, the Defendant imposed and collected property tax of 62,479,620 won, local education tax of 12,495,920 won, property tax of 77,521,010 won, local education tax of 2012, property tax of 77,521,010 won, local education tax of 15,504,200 won, property tax of 77,521,010 won, property tax of 2013, property tax of 77,521,010 won, local education tax of 2013, and local education tax of 15,504,20 won, without justifiable grounds, on the ground that the Plaintiff did not directly use the instant land for the purpose of industrial buildings, etc.

(hereinafter “instant disposition”) e.

The plaintiff is a local tax on March 6, 2015.