Time of transfer of shares at entry;

Even if a transfer is not made due to the closure of the register of shareholders, it is reasonable to see the time of transfer as of the time of liquidation of the transfer price, and it is reasonable to see the transaction price at that time as the normal

Article 52 of the Corporate Tax Act: Denial of Wrongful Calculation

1. The appeal is dismissed.

2. The costs of appeal are assessed against the Defendant.

Although the lower judgment was examined in light of the records of this case, it is recognized that the assertion on the grounds of appeal falls under Article 4 of the Act on Special Cases Concerning Procedure

Therefore, the appeal is dismissed in accordance with Article 5 of the above Act. It is so decided as per Disposition by the assent of all participating Justices on the bench.