The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined.

1. Article 45-2(1) of the former Framework Act on National Taxes (amended by Act No. 911, Jan. 1, 2010) provides that “Any person who has filed a return of tax base within the statutory due date of return may file a request with the head of the competent tax office for the determination or correction of the tax base and amount of national tax initially reported and reported for modification, within three years after the statutory due date of return expires, in any of the following cases.” However, Article 3(2) provides that “where any special provisions exist in the Customs Act and the Special Act on the Refund of Customs, etc. Levied on Raw Materials for Export concerning the national tax imposed and collected by the head of the competent

In addition, Article 4 (1) of the former Customs Act (amended by Act No. 9924, Jan. 1, 2010; hereinafter the same) provides that if the provisions of the Framework Act on National Taxes, the Liquor Tax Act, and the former Customs Act conflict with those of the former Customs Act, the provisions of the former Customs Act shall prevail over those of the former Customs Act.

Meanwhile, Article 23(3) of the former Liquor Tax Act (amended by Act No. 11134, Dec. 31, 201; hereinafter the same) provides that a person who imports alcoholic beverages shall submit a declaration under the Customs Act to the head of the competent customs office at the time of filing an import declaration. Article 38-3 of the former Customs Act provides that “When a person liable for duty payment becomes aware of an excessive amount of duty returned and paid (limited to a case after the period of correction expires)” under paragraph (2) of the same Article, the person liable for duty payment may file a request for rectification of the amount of duty declared, as prescribed by Presidential Decree, with the head of the competent customs office within two years from the date on which the first duty return was filed. In such cases, the head of the relevant customs office in receipt of a request for rectification shall notify