The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

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. Article 30 of the former Customs Act (amended by Act No. 12027, Aug. 13, 2013; hereinafter the same) provides that the dutiable value of imported goods shall be the transaction price adjusted by adding up the amount prescribed in each of the following subparagraphs to the price actually paid or payable by a buyer for the goods sold to be exported to Korea. Article 30 of the former Customs Act provides that the dutiable value of imported goods shall be the transaction price adjusted by a buyer, such as commission and brokerage, to be paid by the buyer for the goods sold to be exported to Korea. Article 30 of the former Customs Act provides that “Where a special relationship prescribed by Presidential Decree between a buyer and a seller affects the price of the relevant goods” under paragraph (3) 4, the transaction price under paragraph (1) shall not

B. In order to apply Article 30(3)4 of the former Customs Act, the lower court: (a) premised on the legal doctrine that the tax authority must prove that the transaction price had been affected by the special relationship, in addition to the fact that there was a special relationship between the purchaser and the seller; and (b) based on its stated reasoning, determined that the special relationship between the Plaintiff and the exporter affected the transaction price of the instant goods

C. Examining the records in accordance with the above provision and related legal principles, the above determination by the court below is just, and contrary to what is alleged in the grounds of appeal, the court below did not err by misapprehending the legal principles on the principle of determining dutiable value under Article 30 of the former Customs Act, failing to exhaust all necessary deliberations, or exceeding the bounds of

2. Ground of appeal.