1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. The reasoning of the court’s explanation concerning this case is as follows, except for the addition of the Plaintiff’s assertion in the relevant part of the trial, and thus, it is consistent with the reasoning of the judgment of the court of first instance. Thus, this is acceptable in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. Matters to be judged additionally;

A. The Plaintiff’s assertion that Article 78(4)1(a) and 2(a) of the former Restriction of Special Local Taxation Act (amended by Act No. 12955, Dec. 31, 2014) provides that real estate acquired by a person who intends to construct industrial buildings, etc. in an industrial complex designated under the Industrial Sites and Development Act (hereinafter “Industrial Sites Act”) shall be exempted from acquisition tax, and Article 39-11(1) of the Industrial Sites Act provides that an industrial complex shall be designated and publicly notified when a renovation project district is designated and publicly notified, the Defendant refused to request the Plaintiff to correct the Plaintiff’s request for rectification on the grounds that the land designated as a renovation project district does not meet the requirements for exemption from acquisition tax prescribed in the said provision, and that the implementation plan should be publicly notified. This is obviously contrary to the provision, which goes beyond the scope of statutory interpretation.

B. Under the principle of no taxation without law, the interpretation of a tax law shall be interpreted in accordance with the text of the law unless there are special circumstances, and shall not be extensively interpreted or analogically interpreted without reasonable grounds. However, where it is necessary to clarify the meaning through the interpretation between the laws and regulations, it is inevitable to make a combined interpretation in light of the legislative intent to the extent that it does not undermine the legal stability and predictability oriented by the principle of no

(see, e.g., Supreme Court Decisions 2007Du4438, Feb. 15, 2008; 201Du17295, Jan. 29, 2014).