Seoul Administrative Court-2016-Gu Partnership-57892 ( November 11, 2016)

Other party to the provision of services, such as deposit withdrawal through ATM

ATM manufacturers and operators will provide services that the bank provides to the Plaintiff with mechanically assisting services provided to the customer and receive fees from the Plaintiff in return.

Article 76 of the Corporate Tax Act

2016Nu7635 Revocation of Disposition of Imposing Corporate Tax

△ Bank Co., Ltd.

The director of the tax office

National Rotations

on October 19, 2017

on October 24, 2017

1. The plaintiff's appeal is dismissed.

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

The judgment of the court of first instance shall be revoked. The defendant shall revoke the disposition of imposition of corporate tax of KRW 96,363,640 against the plaintiff on March 20, 205 (additional Tax on Collection of Evidence) of the year 2009.

1. Quotation of judgment of the first instance;

The court's reasoning concerning this case is as stated in the reasoning of the judgment of the court of first instance except for dismissal or addition of part of the judgment of the court of first instance as follows. Thus, this court's reasoning is cited in accordance with Article 8 (2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

2. Parts to be removed or added;

○ 6th of the second, "the plaintiff is added to "209 year", "the second, the second, the second, the second, the second, the second, the second, adding "the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second, the second,

○ Parts 1 to 5 of the 3rd page shall be deleted.

Then, the 5th 7th th eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth g eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth e

○ 5th page 19, "for the plaintiff," added "if there is a conflict of opinion due to doubt in the interpretation of the tax law beyond a simple scope of land or misunderstanding of the law".

3. Conclusion

Therefore, the judgment of the first instance court is legitimate, and the plaintiff's appeal is dismissed as it is without merit.

It is so decided as per Disposition.