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(1)4 of the former Customs Act (amended by Act No. 10424, Dec. 30, 2010; hereinafter the same) stipulates that “any amount that is paid as a price for the use of a trademark right, etc. and that is calculated as prescribed by the Presidential Decree,” among those adjusted by adding the actual payment price to the actual payment price when determining the dutiable value of imported goods.

In addition, Article 19(2) of the Enforcement Decree of the Customs Act provides that the price for the use of trademark rights, etc. to be added to the actual payment price shall be the amount paid directly or indirectly by the buyer according to the terms and conditions of the transaction in relation to the relevant goods, and Article 19(3)3 of the Enforcement Decree of the Customs Act provides that "if the royalty is paid for the trademark right, the trademark shall be attached to the imported goods or the trademark is attached after the minor processing, such as the dilution mixing, classification, simple assembly and packing, etc.," and Article 19(6) provides that "in addition to the provisions of paragraphs (1)

B. citing the reasoning of the judgment of the court of first instance, the court below: ① the Plaintiff is a wholly owned subsidiary of AB AB AB AB, ABOY, etc. (hereinafter “AB-related company”) from December 1, 2005 to July 2, 2009 (hereinafter “AB-related company”), respectively, imported AC master (hereinafter “the instant first product”), and ② the Plaintiff entered into a trademark use agreement with AB-related company on June 30, 197, and the trademark use agreement replacing the former (hereinafter “the instant trademark use agreement”).