The appeal is dismissed.

Costs of appeal shall be borne by the plaintiff.

The grounds of appeal are examined (to the extent of supplement in case of supplemental statements in the grounds of appeal not timely filed).

1. Judgment on the grounds of appeal Nos. 1 and 2

A. Article 30 of the former Customs Act (amended by Act No. 12027, Aug. 13, 2013; hereinafter the same) provides that the dutiable value of imported goods shall be the transaction price adjusted by adding the amount prescribed in each of the following subparagraphs to the price actually paid or payable by the buyer for the goods sold to be exported to Korea. Article 30 of the former Customs Act provides that the dutiable value of the imported goods shall be the transaction price adjusted by adding the amount prescribed in each of the following subparagraphs, such as commission and brokerage fees to be borne by the buyer for the goods sold to Korea by the buyer. Article 30 of the former Customs Act provides that “Where a special relationship prescribed by Presidential Decree between the buyer and the seller affects the price of the relevant goods, the transaction price prescribed in paragraph (1) shall not be the dutiable value of the relevant goods, and the method prescribed in

B. The lower court: (a) premised on the legal doctrine that the tax office should prove that the transaction price was affected by the special relationship between the purchaser and the seller in order to apply Article 30(3)4 of the former Customs Act by citing or amending the reasoning of the first instance judgment; and (b) based on the reasoning stated in its reasoning, determined that the special relationship between the Plaintiff and the seller was affected by the transaction price of each of the goods of this case.

(c)

Examining the reasoning of the lower judgment in light of the relevant legal principles and records, although the lower court’s reasoning is partially inappropriate, the lower court’s above conclusion is justifiable, and contrary to what is alleged in the grounds of appeal, the legal doctrine on the application of interpretation and application of Article 30(3)4 of the former Customs Act.