1. Revocation of a judgment of the first instance;

2. The Defendant’s customs duties of KRW 282,458,440 as of July 19, 2013 and penalty taxes of KRW 140.

1. Details of the disposition;

A. On January 1, 2010, the Plaintiff completed business registration by designating the location of the business of Daegu North-gu B, trade name C, and business type as trade in fishery products.

B. From August 9, 2010 to October 5, 2012, the Plaintiff imported freezing eggs from Malaysia's exporter, "D", "E", "F", etc. From August 9, 2010 to Malaysia's import price was reported as KRW 67,840,642, while importing Malaysia's freezing 7,010km from "D" to Malaysia's import price was reported as KRW 67,840,642, as well as the import price was reported as KRW 43 times until October 5, 2012, the Plaintiff reported and paid a total of KRW 3,626,172,684 (hereinafter referred to as "reported price declaration" in attached Table 1 as "the declared price" in attached Table 1 as "the declared price" in the same column as "the declared price" in attached Table 25,275,275,474.

C. As a result of the tax investigation with respect to the Plaintiff, the Defendant: (a) denied each of the instant declarations from August 2, 2010 to September 26, 2012; and (b) deemed that the difference was a total of KRW 105 times, total of KRW 1,464,116,290 ($ 1,214,980; USD 1,214,980; USD hereinafter “attached Table 2”) by using the name of a third party as shown in the attached Table 2; (c) deemed that the Plaintiff transferred each of the instant declarations to the Plaintiff at a lower price than the actual import price; (d) denied each of the instant declarations pursuant to Article 30(5) of the Customs Act; (e) Article 35(1) of the Customs Act; (e) Article 29(3)6 of the Enforcement Decree of the Customs Act; and (e) Article 29(1)6 of the former Public Notice on the Determination of Dutiable Value of Imported Goods (amended by Ordinance No. 16516, 14, 7.16.