The legitimacy of the assertion that the processed purchase amount was not leaked out of the company

The processing expenses shall be presumed to have been leaked to the outside of the company unless there are special circumstances. The above special circumstances must be proved by the claimant, and the plaintiff's assertion alone is insufficient to prove this. Thus, the disposition of this case is legitimate.

Article 67 of the Corporate Tax Act

1. The plaintiff's appeal is dismissed.

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

The judgment of the first instance shall be revoked. The imposition of KRW 143,413,220 on global income tax for the year 2002 that the Defendant imposed on the Plaintiff on April 14, 2006 and the imposition of KRW 8,54,360 on global income tax for the year 202 that was imposed on May 1, 2006 shall be revoked.

1. The reasoning of the court's explanation concerning this case is as stated in the reasoning of the first instance court's judgment in addition to using the "written evidence Nos. 3, 5, 8, and 9 of the first instance court's judgment" as the "written evidence Nos. 3, 5, 8, and 9 of the first instance court's judgment No. 6, and evidence No. 8 or 12 of the first instance court's judgment". Thus, it is identical to the written evidence No. 8 (2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

2. If so, the judgment of the first instance is legitimate, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.