The costs of appeal are assessed against the defendant.

1. As to the ground of appeal No. 1, citing the reasoning of the judgment of the court of first instance, the court below acknowledged the following: (a) Plaintiff Han Bank (hereinafter “Plaintiff Bank”) provided money to customers as collateral with a credit guarantee certificate issued by the Korea Credit Guarantee Fund, the Korea Technology Credit Guarantee Fund, various credit guarantee foundations, etc. (hereinafter “credit guarantee agencies”); and (b) the terms and conditions of the credit guarantee agencies applied to the above credit guarantee are commonly stated that “the principal not exceeding the amount of the guaranteed loan multiplied by the ratio of the amount of the guaranteed debt multiplied by the ratio of the guaranteed debt to the amount of the guaranteed debt, and the amount of the accrued interest under the agreed interest rate until the date the guaranteed debt is performed as the guaranteed debt is performed by the credit guarantee agencies; and (c) the Plaintiff bank received the guaranteed loan from the credit guarantee agencies and accounts as the amount of the guaranteed loan principal and the interest on the loan principal under the guarantee rate or the guarantee rate collected each claim; and (d) on the other hand, the Defendant rendered the disposition No. 1 of this case imposing corporate tax on

Then, the lower court determined that it was unlawful to include the interest income in the gross income, on the ground that the total amount of a guaranteed obligation under a credit guarantee contract clearly specifies the principal and interest interest in accordance with the rate of guarantee, and that a credit guarantee agency pays the total amount, and thus, the payment of the payment cannot be applied to the provisions on the application of appropriation under the Corporate Tax Act, etc.

related.