소득금액변동통지처분취소
1. Of the instant lawsuit, the part demanding a change of the results of a tax investigation shall be dismissed.
2. The Defendant is against the Plaintiff on July 16, 2012.
1. Details of the disposition;
A. On January 24, 1998, the Plaintiff was established for the purpose of manufacturing and selling automobile exhaust gas reduction devices, and B served as the Plaintiff’s representative director from March 28, 2001 to July 13, 201.
B. The director of the Central Regional Tax Office of China conducted a tax investigation on the plaintiff (tax item: corporate tax, and the period of investigation: from January 2006 to December 2008), and as a result, he determined that the plaintiff included the processed sales amount of KRW 58,769,00,00 in total, even though the plaintiff did not have any actual sales or actual sales amount of KRW 58,769,000 from 2005 to 2008 (hereinafter the above 58,769,000,000 in total) and then included the processed sales amount of KRW 29,418,089,712 in total in excess of the actual raw materials purchased from E and F from 2006 to 208.
Accordingly, the director of the Central Regional Tax Office of China notified the defendant, who was the head of the competent tax office, of taxation data to dispose of KRW 4,678,153,67, which appears to have been recovered by the plaintiff among the above processing purchase price, as "other", and the remaining KRW 24,739,936,035, excluding the recovered processing purchase price (hereinafter "the pertinent amount") as "credit" against the plaintiff's representative director B, and filed a complaint against B with the head of the competent tax office within the Suwon District Public Prosecutor's Office.
C. Accordingly, on July 16, 2012, the Defendant: (a) deemed that the instant amount of KRW 24,739,936,035 was included in deductible expenses; and (b) as such, it was not clear that the amount was reverted to the company but was leaked to the company; (c) accordingly, the Defendant disposed of the amount of KRW 3,613,962,937,937, the amount reverted to the year 2006, the amount reverted to the year 2007, KRW 10,263,124,219, the amount reverted to the year 2008, and KRW 10,85,571,559, and the amount reverted to the year 2009, KRW 7,277,320, as stated in the attached list, to the Plaintiff on the same day.
(hereinafter “instant disposition”) D.
The Plaintiff is dissatisfied with the instant disposition and on October 12, 2012.