The costs of appeal shall be borne by the defendant.

Article 12(1)1 of the Value-Added Tax Act provides that the value-added tax shall be exempted for unprocessed foodstuffs, and agricultural products, livestock products, fishery products, and forest products not used for food produced in Korea, which are prescribed by the Presidential Decree, and subsequent Article 28(1)1 of the Enforcement Decree of the same Act provides that unprocessed foodstuffs referred to in Article 12(1)1 of the same Act shall be unprocessed or used for food through primary processing to the extent that the inherent nature of the original products is not changed, and Article 10(1) of the Enforcement Decree of the same Act provides that the scope of unprocessed foodstuffs referred to in Articles 28(1) and 40(1)1 of the Decree shall be determined as the attached Table 1, and the same shall exclude the category 12 of the attached Table 1, 12, 40(4) of the same Act, and the same shall include the same in the name of cchip, wreed, wreed, wreed, wreed, and any other similar in the form.

According to the court below's lawful determination, when supplying the salted fish to the non-party 3, a domestic trader, the Plaintiff supplied the salted fish to the non-party 1, the Plaintiff supplied the salted fish to the non-party 1, which is a domestic trader, after putting it into the place of origin and then putting it in the plastic wing box and then then putting it in the hacker box or the hacker lid which can be opened and closed, and the non-party 1, who purchased it, shall transport it to the United States, etc. as soon as possible for the prevention of corruption, keep it in the cooling box, etc. and sell it to the consumers by

The packing under the above Enforcement Decree of the Value-Added Tax Act refers to a package for simple transportation, storage, etc. which does not reach the degree that ordinary consumers can use for food immediately, in light of the purport of the above provision, and it refers to a package packed in the form of the pipe entry, bottle entry, stove entry, and other similar forms of the above Enforcement Rule, which can be promptly used for food by consumers. Therefore, the Plaintiff’s packaging of the salted stove, such as the decision of the court below, is merely a package for transportation, and the supply of the salted s to the extent that the nature of the original products does not change, and thus, the value-added tax is exempted for the supply of the salted s to the extent that it is only the primary processing to the extent that the nature of the original products does not change. Accordingly, the revocation of the disposition of the court below's revocation of the disposition of the value-added tax of this case is just and it does not constitute an unlawful act of unfairly expanding the scope of exemption and recognizing the nature of the salted s to the fish.

Therefore, the appeal is dismissed due to the lack of reason, and the costs of the lawsuit are assessed against the losing party. It is so decided as per Disposition by the assent of all participating Justices.

Justices Lee Chang-chul (Presiding Justice)