Seoul High Court-2018-Nu-43592 (Law No. 19, 2018)

(C) If there is no proof that part of the transfer price was returned, it is dismissed, and there is no reason to believe that the imposition of an additional tax for unfaithful payment is unfair due to the delay of taxation.

(Main) The Plaintiff’s assertion that the transfer value was confirmed due to the details of remittance by the purchaser and that part of the purchase price was returned is legitimate, and there is no reason to believe that no additional tax was paid due to the delay of taxation, and there is no reason to believe that the transfer value was not paid due to the delay of taxation, and the exclusion period of imposition of the transfer

Article 48 of the Framework Act on National Taxes

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined. However, the argument on the grounds of appeal falls under Article 4 of the Act on Special Cases Concerning the Procedure for Appeal, and therefore, the appeal is dismissed under Article 5 of the same Act. It is so decided as