1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The first instance court.

1. The reasons for the court's explanation concerning this case are as follows: (a) deleted 6, 6, 14, and 15 of the first instance court's ruling from "the margin of engine and non-Engine parts is difficult to deem that the margin of the termination rate of engine and non-Engine parts is excessive by 65% and 54%, respectively; and (b) except as added by paragraph (2) below, the judgment on each of the claims made by the plaintiff during the trial is identical to the reasoning of the first instance court's judgment; (c) thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 4

2. Additional determination

A. In addition to the reasons indicated in the judgment of the court of first instance as to whether the calculation of income under the Costs and Expenses Act was unlawful, the judgment of the court of first instance that the Defendant’s instant disposition, which calculated income subject to reduction and exemption pursuant to the Costs and Expenses Act, is justifiable, is justifiable.

① The Plaintiff obtained import by selling an automobile with the instant engine, and the Plaintiff’s separate transaction of the engine is essentially limited, and thus, the engine’s actual engine’s completion vehicle from 2008 to 2010 is merely 12 vehicles (0 vehicles, 2008, 9 vehicles, and 3 vehicles, 2010). The sales price of the engine’s parts agency for maintenance purposes cannot be deemed as the market price formed “when it trades under the ordinary terms and conditions of trade among independent business operators.”

② The Plaintiff asserts that the rate of the termination of engines and non-Engine parts is 65% and 54% respectively, respectively. However, the Plaintiff’s assertion that the rate of the termination of the instant engine is based on the wholesale price of an engine for maintenance, which cannot be deemed as the market price. Therefore, the Plaintiff’s assertion that the cost-based law cannot be applied due to the difference between the rate of the termination of engines and non-Engine parts is difficult.

③ Since the Plaintiff gains profits from the sale of an automobile equipped with the instant engine, the income accrued from the instant engine, etc. shall be the income accrued from the sale of the completed vehicle.