1.The judgment of the first instance shall be modified as follows:

The defendant limited to the plaintiff on October 30, 2006.

1. The reasons for this part of the disposition process are as stated in the corresponding part of the judgment of the court of first instance, with the exception that "before the amendment was made to the Act No. 18796 of Apr. 22, 2005 to the Act No. 18796 of Feb. 28, 2005" as "before the amendment was made to the Act No. 18726 of Feb. 28, 2005."

It shall be quoted in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Whether the instant disposition is lawful

A. The reasoning of this judgment concerning this part of the Plaintiff’s assertion is as stated in the corresponding part of the reasoning of the judgment of the court of first instance, except for the dismissal of the part between six and thirteen in the judgment of the court of first instance as follows.

It shall be quoted in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

Article 18(3) of the Framework Act on National Taxes provides that “after a construction of tax-related Acts or practices in tax administration has been generally accepted by taxpayers, any act or computation according to such construction or practices shall be deemed justifiable, and no tax shall be imposed retroactively by a new construction or practice.” This provision provides that “The disposition on various charges or charges that may be collected in the same manner as delinquent national taxes are collected shall apply mutatis mutandis not only to the taxation administration, but also to the disposition on various charges or charges that may be collected in accordance with the same manner as delinquent national taxes are collected,” and Article 4(2) of the Administrative Procedures Act provides that “ When the construction of Acts and subordinate statutes, etc. or the practices of administrative agencies are generally accepted by the citizens, administrative agencies shall not treat them retroactively and unfavorably, except in cases where there is

However, the defendant not only used for producing heat and self-consumption, but also used for heavy oil produced by petroleum refining business operators as direct collective energy business operators.