1. All appeals filed by the plaintiff and the defendant are dismissed.

2. The costs of appeal shall be borne by each party.

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court, such as accepting the judgment of the court of first instance, is as follows: (a) adding to the corresponding part of the judgment of the court of first instance “related Acts and subordinate statutes” in the corresponding part of the judgment of the court of first instance, “the addition of relevant Acts and subordinate statutes” to the corresponding part of the judgment; and (b) adding or adding the judgment as stated in the reasoning of the judgment of the court of first instance, and (c)

2. Supplement and addition of judgments;

A. The summary of the Plaintiff’s assertion is that the Defendant re-calculated the interest rate recognized as the market price by applying the current interest rate to the market price and included the added portion in the gross income for the following reasons.

(1) Article 89(3) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 23589, Feb. 2, 2012) (amended by Presidential Decree No. 23589, Feb. 2, 2012) amended to apply only the interest rate on overdraft loan to the market price in cases where economic rationality is recognized, such as the weighted average interest rate on overdraft loan at a certain point in the past adjacent to the point of time of lease, is compelling to apply the interest rate on overdraft loan at the market price. Thus, it is invalid in violation of Articles 37(2)

② The Plaintiff’s application of the weighted average loan interest rate at the time most adjacent to the lending point as of the lending point to the market price was reasonable from a normal economic person’s standpoint, and considering the various circumstances of transaction, it does not constitute an abnormal act with economic rationality. Therefore, the Plaintiff’s loan transaction in this case does not constitute wrongful calculation.

(3) Even if the interest rate on overdraft loans prescribed by Ordinance of the Ministry of Strategy and Finance is applied to the market price due to the absence of loans at the time of lending, there is no ground to view that the interest rate on overdraft loans should continue to be applied to the market price.