Framework Act on National Taxes — Article 65-3 (Nemo Judex Sine Actore and Prohibition of Disadvantageous Modification)

(1) In rending a decision under Article 65, the Commissioner of the National Tax Service shall not revoke or modify all or part of disposition, other than the disposition subject to request for examination nor render a decision on a new disposition.

(2) In rendering a decision under Article 65, the Commissioner of the National Tax Service shall not render a decision unfavorable to the claimant than the disposition against which the request for examination was made.[This Article Newly Inserted on Dec. 31, 2018]