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

On June 20, 2006, the Plaintiff is a company incorporated with the business purpose of original Heavy Industries Co., Ltd. (hereinafter referred to as “original Heavy Industries”) and A (10% of shares) by investing KRW 300 million in KRW 300 million.

On July 27, 2007, the Plaintiff purchased assets located in the place of business as of the date of the contract (hereinafter collectively referred to as the “instant real estate, etc.”) at the price of 3,50,000,000,000 won (hereinafter collectively referred to as “the instant real estate, etc.”) from the KSA Co., Ltd. (hereinafter referred to as the “YAP industry”) and the 5,684.87 square meters of the land and buildings thereon, 5,684.87 square meters (a factory area of 5,346.79 square meters, an affiliated building office of 30 square meters, a guard room of 28 square meters, a pumps room of 10.08 square meters; hereinafter referred to as the “instant real estate”), including the said land and buildings, and the machinery, equipment, tools, and appliances, etc., which were located in the place of business as of the date of the contract. On November 2, 2007, the Plaintiff completed the business registration of 200,7.

In applying Articles 64 and 6 of the former Restriction of Special Taxation Act (amended by Act No. 921, Jan. 1, 2010; hereinafter “former Restriction of Special Taxation Act”), the Plaintiff filed each declaration of KRW 287,168,332 as corporate tax in 2009, KRW 451,037,130 as corporate tax in 2010, and KRW 426,465,00 as corporate tax in 2011.

The Defendant determined that the instant real estate, etc. cannot be deemed a business property of a small or medium start-up start-up enterprise because the Plaintiff’s acquisition or purchase of the assets used for the previous business and conducted the same type of business, etc., as prescribed by Article 6(4)1 of the former Restriction of Special Taxation Act, is not subject to corporate tax reduction or exemption pursuant to Articles 64 and 6 of the former Restriction of Special Taxation Act. On November 1, 2013, the Defendant applied Article 7 of the former Restriction of Special Taxation Act to the Plaintiff on 160,04,650 (including additional tax 45,17,322) of corporate tax in 209.