1. The part of the judgment of the court of first instance against the plaintiff, which orders revocation below, shall be revoked.

Defendant.

1. The reasons why this Court is used for this part, such as the background of the disposition, are as stated in Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act, except in the case of dismissal by land or by sea, since it is identical to the reasoning of the judgment of the first instance except in the case of dismissal by land or by sea.

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) The instant disposition was unlawful on the premise that the instant goods meeting the requirements for deeming direct transport under Annex II to this Agreement meet all the requirements for deeming direct transport, and there is no ground to limit the documentary evidence to the transit bill of lading for verifying the requirements for deeming direct transport. On the other hand, Article 8(3) of the Rules on the Criteria for Confirmation of Origin, etc. of the Asia-Pacific Trade Agreement changes the scope of tariff concessions by reducing the scope of tariff concessions and thus is null and void beyond the scope of delegation under this Agreement. Accordingly, the instant disposition is deemed null and void as it goes beyond the scope of delegation under this Agreement. Accordingly, even if it is assumed that the instant bill of lading must be submitted as documentary evidence to verify the requirements for direct transport, the instant disposition is in violation of the principle of non-taxation or the protection of trust, and thus, it has already been established as non-taxation practice on the fact that Cheongman has already been recognized as documentary evidence of the requirements for deeming direct transport.

In addition, the Defendant expressed not only prior to the enactment of the rules on the criteria for verifying the origin of the Asia-Pacific Trade Agreement, but also the public opinion continuously recognizing the hearing as the documentary evidence of the requirements for direct transport. Thus, the instant disposition is unlawful in violation of the principle of trust protection.

(b) the relevant statutory provisions;