1. Of the judgment of the court of first instance, the part against the defendant regarding the imposition of corporate tax for the business year 2001 and 2002 shall be revoked and above.

1. In the first instance court, the Plaintiff sought the revocation of the disposition imposing corporate tax for each business year of 1999, 200, 2001, and 202, and the judgment of the first instance court accepted the Plaintiff’s claim.

The defendant appealed against this, and the judgment of the appellate court (the judgment prior to the remand) dismissed the defendant's appeal.

The defendant appealed, and the judgment of the court of final appeal (the judgment of the court of final appeal) reversed the part of the part against the defendant regarding the imposition of each corporate tax for 2001 and 2002, and remanded this part of the case to this court.

(1) The Plaintiff’s appeal against the disposition of imposition of each corporate tax for the business year of 1999 and 2000 was dismissed and final and conclusive. Following the remand of the case, the Plaintiff reduced the amount of corporate tax for the business year of 2001 by ex officio reduction and correction of the amount of corporate tax for the business year of 2001.

Therefore, the scope of this court's trial after remand is limited to each corporate tax of 2001, 2002.

2. The reasons why this court should explain concerning this part of the reasons for the decision of the court of first instance are as stated in the corresponding part of the reasons for the decision of the court of first instance (the corresponding part of the grounds for the decision of the court of second instance from 6 to 4, and the corresponding part of the grounds for the decision of the court of first instance). As such, this part of the reasons are cited in accordance with Article 8(2)

The part in which they are used shall be deleted from all the entries of the title No. 14 to No. 16.

The following shall be added to not more than 22 pages:

(E) On September 23, 2014, the Defendant revoked ex officio KRW 87,060,541 of the corporate tax of 2,212,419,96 on September 23, 201 (hereinafter “the disposition of imposition of corporate tax of 2,125,359,455 and the disposition of imposition of corporate tax for the business year of 2002”).

[Judgment]

3. Whether the instant disposition is lawful

A. 1) The parties’ assertion 1) The arm’s length price is based on the comparable company when assessing the transfer price.