1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court in this case concerning the acceptance of the judgment of the court of first instance is as follows. The judgment of the court in this case is dismissed as the "passive examination" of the 11th of the judgment of the court of first instance, and the judgment of the parties in this case is added as follows. Thus, it is identical to the part of the judgment of the court of first instance, and thus, it is acceptable in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article

2. Additional determination

A. 1) The Plaintiff’s assertion 1) The gist of the Plaintiff’s assertion is that the Plaintiff Co., Ltd. (hereinafter “C”) around December 2015.

1) The agreed amount of KRW 1 billion (hereinafter “instant agreed amount”)

(2) Even if the payment of the Plaintiff’s payment does not constitute a ground for filing a subsequent claim for correction under Article 45-2(2) of the Framework Act on National Taxes, it constitutes a ground for filing a general claim for correction under Article 45-2(1) of the Framework Act on National Taxes, and thus, it constitutes a ground for filing a request for correction under Article 45-2(1) of the Framework Act on National Taxes. The Plaintiff’s refusal of correction of the instant case is unlawful. (2) The amount of global income tax return pertaining to “B” for the year 2011 and year 2012, is KRW 1,238,309,958, and the amount of income claimed by the Plaintiff in the instant request for correction is KRW

In other words, the plaintiff's request for correction of global income tax does not seek a reduction of the tax base and tax amount originally reported, but the defendant sought a reduction of the increased tax base and tax amount on December 1, 2014.

Therefore, the plaintiff's request for correction of global income tax is unlawful as a general claim for correction under Article 45-2 (1) of the Framework Act on National Taxes, since 90 days have passed since the defendant became aware of the increase

B. The taxpayer who filed a tax base return on the Defendant’s assertion within the statutory due date of return, did not dispute within the prescribed objection period with respect to the decision or disposition made by the tax authority due to the correction.