The judgment below is reversed and the case is remanded to Seoul High Court.

The grounds of appeal are examined.

1. Article 45-2(2) of the former Framework Act on National Taxes (amended by Act No. 13552, Dec. 15, 2015; hereinafter the same) provides that “Any person who has received the determination of the tax base and amount of national taxes may file a request for correction within two months from the date on which he/she becomes aware of the occurrence of any of the grounds falling under any of the following subparagraphs.” Thus, a request for correction filed after the lapse of the period for filing the request for correction is illegal and thus the tax authority is not obligated to determine or rectify the tax base and amount of tax, or to take a disposition of refusal, and thus, even if the tax authority

(1) Article 45-2(2) of the former Framework Act on National Taxes (amended by Presidential Decree No. 20101, Nov. 27, 2014; hereinafter “amended by Presidential Decree No. 20135, Nov. 27, 2014”) provides for the following reasons: (a) the period for filing a subsequent request for correction does not fall under the grounds for subsequent request for correction; and (b) the period for filing a subsequent request for correction does not fall under the grounds for subsequent request for correction; (c) so long as the period for filing a subsequent request for correction does not fall under the grounds for subsequent request for correction on the grounds that the taxpayer had no existing at the time of filing the initial return or taxation; and (d) the period for filing a request for correction after the expiration of the statutory due date for filing the relevant national tax base and the amount of tax; and (d) the legal effect thereof vary, the period for filing a subsequent request for correction, barring any special circumstance, shall be deemed as the date when the relevant grounds arises.