1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On December 201, the director of the Central Regional Tax Office of China conducted a tax investigation with respect to B Co., Ltd. (the trade name before the change is “C Co., Ltd.” hereinafter) and notified the Defendant of the taxation data that the Plaintiff borrowed KRW 500 million to Nonparty Co., Ltd during the taxable period in 2007 and 2008, and the interest income accrued after lending KRW 500 million to Nonparty Co., Ltd. was KRW 180,000,000 and KRW 144,00,000 in 208.

B. Accordingly, the Defendant, on September 1, 2012, notified the Plaintiff of the global income tax of KRW 8,479,560 and global income tax of KRW 6,970,000 for the global income tax of KRW 180,000 for the year 207 and KRW 144,00,000 for the year 208.

On the other hand, in the review of the legality before taxation, it was revealed that interest income of 30,00,000 won accrued in 207 was excessively appropriated, and there was a need to correct the portion deducted from the already paid tax amount. On November 9, 2012, the Defendant issued an additional notice to the Plaintiff on November 9, 2012, by adding the global income tax of 54,146,810 won accrued in 2007 and the global income tax of 49,489,200 won accrued in 208.

(hereinafter referred to as “instant disposition” in total, both the imposition of September 1, 2012 and the imposition of November 9, 2012.

On December 5, 2012, the Plaintiff dissatisfied with the instant disposition, and filed an appeal on December 5, 2012, and the Tax Tribunal rendered a decision on March 21, 2013 that “The Plaintiff’s interest income re-audits the Plaintiff’s interest income and changes the tax base and tax amount according to its results.”

Accordingly, the defendant notified the plaintiff on April 26, 2013 that the initial disposition should be maintained as it is after re-audit.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 10, 11, Eul evidence Nos. 1, 2 and 3 (including branch numbers), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion around July 18, 2007 lent KRW 500 million to E, the representative director of the non-party company, by introducing D around July 18, 2007.