Of the part against the Defendant of the lower judgment, the term “justifiable amount of tax” in the imposition of customs duties indicated in the attached Table.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. As to the Plaintiff’s grounds of appeal, the lower court acknowledged facts as indicated in its reasoning after comprehensively taking account of the adopted evidence, and determined that it was lawful to determine the dutiable value on the basis of the transaction price of similar goods under Article 32 of the former Customs Act (amended by Act No. 11602, Jan. 1, 2013; hereinafter the same) by deeming the Plaintiff’s import declaration price as the transaction price of similar goods under Article 32 of the former Customs Act (amended by Act No. 11602, Jan. 1, 2013; hereinafter the same) on the grounds that there exists reasonable grounds to suspect the accuracy or truth of the declared price, such as where the price reported by the Plaintiff while importing goods listed in the [Attachment No.

In light of the relevant legal principles and records, the above determination by the court below is justifiable. Contrary to the allegations in the grounds of appeal, the court below did not err by exceeding the bounds of the principle of free evaluation of evidence against logical and empirical rules, or by misapprehending the legal principles on the requirements for denial of transaction price and the burden of proof under Article 30 of the former Customs Act, and the transaction price of similar

2. As to the Defendant’s ground of appeal

A. After compiling the adopted evidence, the lower court acknowledged the facts as indicated in its reasoning, and found it lawful for the Defendant to deny the Plaintiff’s import declaration price on the goods listed in the [Attachment 1] through 3] of the lower judgment, but on the ground that the import declaration price of the Han River (US$ 498.2 per ton US$) imported by farming water is the minimum transaction price of similar goods under Article 32 of the former Customs Act, the lower court’s determination of the dutiable value should be based on this.