1. The Defendant (Counterclaim Plaintiff) paid KRW 446,848,901 to the Plaintiff (Counterclaim Defendant) and its amount from March 22, 2011 to September 11, 2012.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. The Plaintiff as a party is a company that conducts the control business, the high-pressure gas sales business, the filling and manufacturing of liquefied petroleum gas, etc., and the Defendant Company (hereinafter “Defendant Company”) is a company that conducts liquefied business, the collective supply business of petroleum gas, etc.

B. (1) The Plaintiff Company received liquefied petroleum gas (hereinafter “instant liquefied petroleum gas”) from the Defendant Company as materials for household carbon gas, and liquefied petroleum gas was changed from the Individual Consumption Tax Act to Act No. 8829 on December 31, 2007.

Article 1(1) and (2) 4 (f), Article 3 of the Individual Consumption Tax Act and Article 1 of the Individual Consumption Tax Act shall be imposed on specific goods, admission to specific places, and business activities at specific places.

(2) The goods subject to the individual consumption tax (hereinafter referred to as "taxable goods") and their tax rates are as follows:

4. The applicable tax rates shall apply to the volume of the following goods:

(f) The individual consumption tax shall be levied on butane (including mixtures of propane and butane, which does not fall under item (e)) among petroleum gases;

(2) Accordingly, the Plaintiff Company has paid value-added tax on the value of supply calculated by adding individual consumption tax, etc. to the value of goods to the Defendant Company.

(3) Meanwhile, the Defendant Company, as a liquefied petroleum gas-related business operator selling butane for household use to liquefied petroleum gas sellers, etc., manufactures or imports goods under Article 1(2)4 (f) that are used for cooking, heating and other purposes as determined by the Presidential Decree (hereafter in this Article “bane for household use”) from liquefied petroleum gas-related business operators who sell butane for household use to liquefied petroleum gas sellers, etc.