All appeals are dismissed.

Costs of appeal shall be borne by each party.

The grounds of appeal are examined.

1. Plaintiff’s ground of appeal

A. As a matter of principle, taxes on the first return method of tax payment is determined by the taxpayer’s self-determination of tax base and amount of tax, and the payment is determined by the taxpayer’s act of filing a return, and the State holds the amount of tax paid based on the final tax claim. As such, insofar as the taxpayer’s act of filing a return does not automatically become invalid due to a grave and apparent defect, it shall not be deemed as unjust enrichment.

In this context, the purpose, meaning, function, and legal remedies for defective reporting acts should be considered as a basis for the act of filing a report in a teleological context, and the specific circumstances leading to the act of filing a report should be individually identified and reasonably determined.

(See Supreme Court Decision 2006Da63464 Decided February 8, 2007, and Supreme Court Decision 2006Da81257 Decided April 23, 2009, etc.). Based on its stated reasoning, the lower court determined that the act of reporting in this case cannot be deemed as an act of reporting in this case’s case’s grounds, and thus, it is difficult to view that the act of reporting in this case’s case’s act

Examining the records in light of the aforementioned legal principles, although the court below’s reasoning was somewhat inappropriate, the conclusion that rejected the Plaintiff’s assertion is acceptable. In so doing, contrary to what is alleged in the grounds of appeal, the court below did not err by misapprehending the legal principles on the invalidity of corporate tax

B. The second ground for appeal contains a period during which the taxpayer is unable to make a request for correction after the period for filing a request for correction expires, although the head of a tax office or the director of a regional tax office ex officio

Even if the tax authorities make an error in the content of the report.