The appeal is dismissed.

The costs of appeal are assessed against the defendant.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. Regarding ground of appeal No. 1

A. Before the former Framework Act on National Taxes was amended by Act No. 12848, Dec. 23, 2014

(a) The same shall apply;

Article 45-2(1) main sentence and 1 of Article 45-2(1) are “person who has filed a return of tax base by the statutory due date of return” means the tax base and amount of tax recorded in the return of tax base (where a determination or correction is made pursuant to the tax-related Acts,

If it exceeds the tax base and amount to be reported under this tax-related Acts, the decision or rectification of the tax base and amount of the national tax for which the initial return or revised return was filed may be requested to the head of the competent tax office within three years after the statutory due date

Meanwhile, Article 134 (1) of the Enforcement Decree of the Income Tax Act refers to the date of receipt of a notice of change in the amount of income under Article 192 (1) (referring to the resident where a resident is notified pursuant to the proviso to the part other than each subparagraph of Article 192 (1)) by the relevant corporation (referring to the date of filing a corporate tax return where the amount included in gross income is changed by a corporation by filing a report on the tax base of corporate tax, or by determining or revising the corporate tax base pursuant to the Corporate Tax Act, as the amount included in gross income is disposed of as dividends, bonuses, or other income; a person who does not make a final return on the tax base of global income pursuant to the tax-related Acts;

When an additional return is filed by the end of the month following the month to which this belongs, the deadline specified in Article 70 or 74 of the Act.