1. Revocation of the first instance judgment.

2. On November 26, 2013, the Defendant reverted to the Plaintiff on November 26, 2013 46,688.

1. Details of the disposition;

A. The Plaintiff (only “Plaintiff,” regardless of whether it was established before or after the division, was divided from the golf-based capital brokerage, which was established on January 26, 2015, is a company with the purpose of manufacturing, selling, and services for golf products, golf practice ranges, golf course businesses, screen golf business, etc., and operates a department in exclusive charge of research and development on manufacture, such as screen golf, 207.

3. On 28. 28. The head of the Korea Industrial Technology Association, an incorporated association, recognized a research institute affiliated with a company that is a second company affiliated with the company (hereinafter “instant research institute”) as a research institute affiliated with a company as prescribed by the Technology

B. Until the business year 2007 to 2010, the Plaintiff disbursed the total of KRW 820,468,556,00 for retirement pension premium for the employees working at the instant research institute, including KRW 44,431,867 for the business year 2007, KRW 88,145,00 for the business year 2008, and KRW 203,089,626 for the business year 2009, and KRW 484,802,063 for the business year 20,468,556 for the employees

(hereinafter “Retirement Pension Contribution of this case”). C.

The Plaintiff’s “research and human resources development expenses omitted at the time of filing a corporate tax return for 2004 through 2006” and “retirement pension premium” with the head of Seo-gu Daejeon District Tax Office on December 9, 201, shall be deemed to be the “tax credit under the Restriction of Special Taxation Act” under Article 10(1) of the former Restriction of Special Taxation Act (amended by Act No. 9272, Dec. 26, 2008; Act No. 9921, Jan. 1, 2010; Act No. 10406, Dec. 27, 2010; Act No. 11133, Dec. 31, 2011; hereinafter collectively referred to as “former Restriction of Special Taxation Act”).

In accordance with the target research and human resources development expenses, 319,261,426 won of corporate tax for the business year 2007, 356,872,797 won of corporate tax for the business year 2008, 747,793, 173 won of corporate tax for the business year 2009, and 2,190,671,673 won of corporate tax for the business year 2010.

2.3.