Seoul Administrative Court-2015-Gu Partnership-71488 ( April 14, 2016)

Cho Jae-2014-west-5722 (Law No. 14, 2015)

Unless special circumstances exist, the evidence of the certificate cannot be readily denied only.

(as in the judgment of the first instance court) Unless there are special circumstances, evidence of the written confirmation cannot be readily denied. It shall be concluded that a written confirmation of a processing benefit is not included in deductible expenses as a processing cost unless there is any evidence to reflect this after the written confirmation of the content of the processing benefit.

Article 19 (Scope of Losses) of the Corporate Tax Act, Article 67 (Disposition of Income) of the Corporate Tax Act

2016Nu4348 Revocation, etc. of Disposition of Corporate Tax Imposition

AA Corporation

BB Director of the Tax Office

Seoul Administrative Court Decision 2015Guhap71488 decided April 14, 2016

October 14, 2016

November 4, 2016

1. The plaintiff's appeal is dismissed.

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

The judgment of the court of first instance shall be revoked. The decision of the court of first instance rendered by the defendant on May 7, 2014 by the defendant to the plaintiff on May 7, 201, ① the portion exceeding 000 won of corporate tax of 2009 (including additional tax), ③ the portion exceeding 000 won of corporate tax of 2010 won (including additional tax), ③ the portion exceeding 000 won of corporate tax of 2000 won in the business year of 2011, and ② the portion exceeding 00 won of corporate tax of 2000 won (including additional tax), ② the portion of the notice of change in income amount of 209, Jaaa year to which the income earner belongs, the portion exceeding 00 won of the notice of change in income amount of 00 won in 200 won, the year to which the income amount is reverted, the notice of change in income amount of 200 won in 201, the year to which the income amount is reverted, and each disposition is revoked.

1. Quotation of the reasons for the judgment of the first instance;

This judgment is identical to the reasoning of the judgment of the court of first instance, and thus, it is cited by Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

2. Conclusion

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