법인세부과처분취소
1. The defendant's appeal is dismissed.
2. The costs of appeal shall be borne by the Defendant.
Purport of claim and appeal
1...
1. The reasoning of the court’s explanation of this case is as stated in the reasoning of the judgment of the first instance except for dismissal or addition of the judgment of the first instance as follows. Thus, this is accepted in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.
2. Parts in height:
(a) Rule 12-13 of the judgment of the first instance court with "unit cost of labor cost" as "the highest price out of the unit cost of labor cost";
(b) at the bottom of six pages of the first instance judgment, 5 m. “B No. 21 m. 1” means “B No. 21 m. 1.”
(c)on 7 pages 11 of the first instance judgment, the phrase “A No. 11” shall read “A No. 11, No. 38-4 of the first instance judgment;
(d) On April 30, 2008, the first instance court’s 7th 10th 7th 10th am “facts” is that “the fact, future cambs and 21th ambs and information system operations personnel (one to 50 ambs and two-one ambs) and subsequent basic expenses for IT ambs and information system (one to 4,764,00,000 from KRW 4,764,00,000 to KRW 2,15,00,000) will be put into the half year’s level
E. In full view of the statements in Gap evidence Nos. 8, Eul evidence Nos. 8, Eul evidence No. 23-2, and Eul evidence Nos. 23-2 and the purport of the whole pleadings in the testimony of witness A at the court of first instance at the bottom of 7th trial, there are cases where a contract is concluded by setting the unit cost of labor cost (indirectly cost) without increasing inputs, if the level of service required under the contract is higher than the level of service required under the contract. In light of the fact that the plaintiff seeks to reduce the cost by assessing part of inputs under the contract of this case at a level lower than the actual technical grade, the defendant's assertion that the unit cost of labor cost, not the total service cost, should be compared is not accepted.
(f) On 8 pages 5 of the first instance court ruling, “one” added the following and otherwise the publicly notified unit price for SamsungSI and Samsung C&M around 2008.