In the case where the district director makes a Reassessment or determination with regard to corporation tax on income pertaining to the domestic source income listed in Article 141, item (i), (a) (Tax Base) (hereinafter referred to as "income attributable to a permanent establishment" in this Article) for each business year of a foreign corporation, when it is found that any acts or calculations of the foreign corporation would, if allowed, result in unreasonably reducing the burden of corporation tax through an increase in the amount to be deducted from the amount of income pertaining to the income attributable to a permanent establishment for each business year, an increase in the amount to be deducted from the amount of corporation tax on income pertaining to the income attributable to a permanent establishment for each business year, a decrease in the amount of profit or an increase in the amount of loss pertaining to internal transactions prescribed in Article 138, paragraph (1), item (i) (Domestic Source Income), or any other grounds, the district director may, notwithstanding the acts or calculations, calculate the tax base of corporation tax on income pertaining to the income attributable to a permanent establishment, the net operating loss, or the amount of corporation tax on income pertaining to the income attributable to a permanent establishment of the foreign corporation for each business year, based on their own recognition.