1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. Details of the disposition;

A. From September 2010 to July 2014, the Plaintiff imported a total of 924.84 tons of the dried and Dried Dried Dried Dried Duna, processed from two enterprises located in China, on 53 occasions (hereinafter “instant goods”), and reported the import price to USD 480 per ton in US currency.

B. The Defendant denied the Plaintiff’s import declaration price on the grounds that “The import declaration price of the instant goods is USD 1,165 to 3,218 per ton, which is the import declaration price of similar goods, and USD 1,378 to 5,147 per ton, which is substantially lower than that of USD 1,378 to 5,147 per ton,” and determined the dutiable value based on the origin investigation price of a distribution corporation pursuant to Article 35 of the Customs Act. On July 14, 2015, the Defendant notified the Plaintiff of the increase in customs duties (including additional duties) as shown in the attached list.

(hereinafter “instant disposition”). C.

On September 7, 2015, the Plaintiff appealed and filed a tax appeal with the Tax Tribunal.

On June 29, 2016, the Tax Tribunal rendered a decision that “The dutiable value of the instant goods shall be re-surveyed in consideration of the quality difference between the instant goods and the mountainous district investigation price, and accordingly, the tax base and tax amount shall be corrected according to the result of re-survey of the instant goods in calculating their dutiable value according to the method prescribed in Article 35 of the Customs Act, considering the quality difference between the instant goods and the relevant goods and the relevant mountainous district investigation price.”

(hereinafter “instant re-audit decision”) D.

On October 20, 2016, the prices of distributed construction works are reflected in various factors, such as standards, time, market demand supply conditions, etc.

The goods of this case are quality.