1. The defendant's appeal is dismissed.

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

3.Paragraph 1 of the text of the judgment of the court of first instance.

1. The reasons for the court’s explanation concerning this case are as follows, except for the addition of “determination on the Defendant’s argument” under Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act, and thus, the same shall be cited in accordance with the reasoning for the judgment of the first instance.

2. Judgment on the defendant's argument of the trial

A. Defendant’s assertion 1) The special discount price agreed upon by the Plaintiff when entering into an import contract for the instant goods from YH Q constitutes grounds for exclusion from the application of the transaction price in determining the dutiable value for the following reasons. ① At the time of entering into the import contract, the Plaintiff traded the instant goods at a special discount price under the condition that the Plaintiff only sold the instant goods to Y&C and supplied them only to YSSF Co., Ltd., and this constitutes grounds for exclusion from the application of the transaction price under Article 30(3)1 of the Customs Act. ② There is a special relationship between the Plaintiff and the seller, the buyer, and the head office of Japan, the buyer, YH Q, and distort the import price of the instant goods, which affected the import price of the instant goods, so this constitutes a ground for exclusion from the application of the transaction price under Article 30(3)4 of the Customs Act. 2) If the application of the transaction price is excluded from the application of the method of determining the dutiable value of the instant goods, following the customs laws and regulations shall be applied in order.

The second method (the transaction price of the goods of the same kind and quality) shall apply to some of the goods of this case, and the third method (the transaction price method of similar goods), fourth method (the method based on the domestic sale price), and fifth method (the method based on the calculation price) shall not be applied to most of the other goods, and the six method (the method based on the reasonable criteria) shall be applied, and the second through fifth method shall also be applied to the six method.