Where the processing purchase amount and the processing sales amount have occurred in the same business year, the scope of the outflow;

The burden of proof that the processing purchase amount was not out of the company is the person who asserts it, and there is no evidence to prove that the processing purchase amount was appropriated as the provisional receipts, but it was treated as the provisional receipts at the time of the recovery of the processing sales, so the disposition of this case where the processing purchase amount was recognized as the representative is legitimate.

Article 67 of the Corporate Tax Act

1. The plaintiff's appeal is dismissed.

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

The part of the judgment of the first instance against the plaintiff shall be revoked.

The part exceeding KRW 582,940,152 of the disposition imposing global income tax of KRW 1,545,339,00 for the Plaintiff on March 4, 2004 which the Defendant imposed on the Plaintiff on the Plaintiff on March 4, 200 shall be revoked.

The reasoning for the court's explanation on this case is as follows: "The statements of No. 6-1,2, and4 of evidence No. 6-1,2, and 8-10 of the judgment of the court of first instance" are as follows: "The testimony of No. 6-1,2, and 4 of the evidence No. 6-1,24 of the judgment of the court of first instance and the testimony of No. 6-1,24 of the witness of the court of first instance is used"; therefore, it is identical to the statement of the reason for the judgment of the court of

Therefore, the judgment of the first instance court is just in its conclusion, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.