이 사건 가공매입원가 중 김CC에 귀속된 부분을 포함한 이 사건 가공매입원가 전체를 김BB에게 과세한 처분은 위법함[국패]
Seoul High Court 2012Nu27260 (No. 23, 2013)
early 201J 2971 ( December 13, 2011)
The disposition imposing all of the instant processing purchase costs on KimB, including the part reverted to KimCC among the instant processing purchase costs, is unlawful.
Since some of the processing costs of this case are reverted to KimCC, the disposition imposing tax on the processing costs of this case considering the whole of the processing costs of this case as KimB's income is unlawful.
Article 67 of the Corporate Tax Act
2013Du20318. Revocation of notice of change in income amount
AA Industry Corporation
The director of the Southern Incheon District Office
Seoul High Court Decision 2012Nu27260 Decided August 23, 2013
The appeal is dismissed.
The costs of appeal are assessed against the defendant.
The records of this case and the judgment of the court below and the grounds of appeal were examined. However, the grounds of appeal by the appellant are not included in the grounds prescribed in each subparagraph of Article 4(1) of the Act on Special Cases Concerning the Procedure for Appeal, and the appeal is dismissed in accordance with Article 5 of the same Act. It is so decided as per Disposition by the assent of