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(영문) 서울고등법원 2016.09.29 2016누36484
소득금액변동통지 취소
Text

1. The plaintiff's appeal is all dismissed.

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

Purport of claim and appeal

The first instance court.

Reasons

The reasoning of the judgment of the court of first instance is as follows, and it is consistent with the reasoning of the judgment of the court of first instance, except for the addition of the judgment as to the plaintiff's argument in the court of first instance to the following paragraph (2). Thus, it shall be cited in accordance with Article 8 (2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

Part 2, 8, "Representative Director" shall be dismissed or deleted as the "Chairperson".

Part 2, Paragraph 12 (hereinafter referred to as “instant disposition”) shall be deleted.

The “total” shall be added to the partitions below the last part of the content of the year 2009 in the second Schedule.

Part 3: The following shall be added to the second page:

D. On July 31, 2014, C filed an objection against global income tax amount attributed to the Defendant for the business year of 2008. According to C’s decision to re-audit the foregoing objection, the Defendant, on November 17, 2014, determined to reduce the amount of global income from the initial income disposition amount on the ground that the amount of KRW 100,000,000,000 in total, “E processing loans” and KRW 570,000,000 in “F processing loans” as indicated in the above table, was not included in the processed loans as indicated in the crime list 2,000,000 in the relevant criminal case judgment against C (Seoul Central District Court Decision 201Da81, Feb. 3, 2012, etc.) and the Defendant’s decision to reduce the amount of income from the amount of income to 208 business year of 6,729,900,000, 2014.

3) Part III “Nos. 10, 18” is added to “Nos. 1 through 3.”

Part 4, "the original collection limit" in Part 19 shall be deemed to be "the withholding limit".

Part 6, "Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 26981, Feb. 22, 2016)" shall be added next to "Enforcement Decree of the Corporate Tax Act".

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