1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1..

1. The reasons why the court has used this part of the disposition are as stated in the part concerning “1. The reasons for the judgment of the court of first instance,” and thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. The parties' assertion and judgment

A. 1) The Plaintiff’s assertion 1) ① The Plaintiff’s declaration price cannot be deemed to be significantly different from the transaction price of the goods of the same kind and quality or similar goods, and ② there are reasonable grounds to suspect the accuracy or truth of the Plaintiff’s declaration price.

Inasmuch as the instant disposition denying the Plaintiff’s reported price cannot be deemed as a dutiable value, the instant disposition that denied the reported price is unlawful.

B) The instant disposition is unlawful as it determines the dutiable value based on the price not meeting the requirements of Article 31(1)2 of the Customs Act, namely, “the transaction stage, volume, distance, and mode of transport, etc. of the relevant goods.” If there is a difference between two goods, the price adjusted accordingly.” (2) Defendant A) ① The Plaintiff’s declared price is lower than 14.4% or 15.1% than the minimum price of the similar goods recognized as the dutiable value, and is lower than 2.9% or 23.5% than the base price of the imported goods guaranteed by the Korea Customs Service. Around May 2012, the Korea Customs Service’s investigation conducted at the Korea Customs Service, there is a significant difference between the transaction price of the goods of the same kind and quality or similar goods, and ② the exporter’s profit is excessively less than the market price of the goods of the same kind and quality or similar goods, compared with the export content of the Korea Fisheries & Food Distribution Corporation, and thus, the Plaintiff’s declaration price of the instant goods is correct.