당초처분이 여러 차례에 거쳐 감액경정처분 되었다면 각 경정처분시마다 차액상당의 국세환급청구권이 발생하는 것임.[국승]
Daegu High Court 2012Na20568 (Law No. 104, 2013)
If the initial disposition of reduction is made through several times, the claim for refund of national tax equivalent to the difference will occur at each time of the corrective disposition.
If the original disposition is taken for reduction through several times, each disposition for reduction shall have a claim for refund of each national tax equivalent to the amount of tax payable after deduction on the date of the disposition, and the extinctive prescription of the claim for national tax refund shall run from the date of each disposition.
Article 54 of the Framework Act on National Taxes
2013Da204614 National Tax Refund
1.ThisA 2.B. 3. RoCC 4.DD 5.E 6.F
Korea
Daegu High Court Decision 2012Na20568 Decided April 10, 2013
All appeals are dismissed.
The costs of appeal are assessed against the plaintiffs.
All of the records of this case and the judgment of the court below and the grounds of appeal were examined. However, the grounds of appeal on the grounds of appeal are not included in the grounds provided by each subparagraph of Article 4(1) of the Act on Special Cases Concerning the Procedure for Appeal, and all of the appeals are dismissed pursuant to Article 5 of the same Act. It is so decided