1. Revocation of the first instance judgment.

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

1. The reasoning of the judgment by the court, such as the background of the disposition, is the same as that of the judgment of the court of first instance, and thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure

However, the letter 7 of the judgment of the court of first instance is divided into three parallels, seven parallels, "third parallels", and "third parallels" into "third parallels of the court of first instance" and "five parallels of the court of first instance", respectively.

2. Each disposition of the Plaintiff’s assertion of this case should be revoked on the following grounds.

The interest at issue does not constitute domestic source income.

1) The interest at issue is the return of unjust enrichment that is paid as a result of the cancellation of each shipbuilding contract at issue. Therefore, the interest at issue is the return of unjust enrichment that is paid to the original state following the cancellation of each shipbuilding contract at issue. Therefore, Article 93 Subparag. 11 (b) of the former Corporate Tax Act and the Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 22577, Dec. 30,

(2) Article 132(10) of the Corporate Tax Act, Article 93 subparag. 10(b) of the Corporate Tax Act, or Article 93 subparag. 10(10) of the Enforcement Decree of the Corporate Tax Act does not constitute “money received in excess of compensation for payment under the original terms and conditions of the contract, as compensation for damages, which is paid due to breach or termination of a contract on property rights.” Even if the interest at issue falls under the interest rate, the interest rate at issue is the compensation for damages paid to the foreign vessel owner in order to compensate for the actual damages, and thus does not constitute “money received in excess of compensation for the payment itself under the original terms and conditions of the contract.” (2) Foreign vessel owners do not constitute “money received in excess of compensation for the payment itself under the original terms and conditions of the contract.” As such, the interest at issue cannot be deemed as falling under other income under Article 93 subparag. 11(j) of the former Corporate Tax Act or Article

3 Foreign vessel owners.