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

A. The Plaintiff, as a juristic person operating food business, etc., was equipped with manufacturing facilities, and was supplied by packaging in an independent transaction unit for the purpose of sale, and filed a return on and payment of each value-added tax equivalent to the amount indicated in the column of “sale tax amount” in the attached Table 1 from January 1, 2012 to February 2016 (hereinafter “instant products”).

B. The Plaintiff asserted that the instant product constitutes subject to value-added tax exemption, and filed a claim for correction with the Defendant to refund value-added tax on the instant product on July 25, 2017 and January 2, 2012 to January 8, 2018. However, the Defendant applied Article 26(1)1 of the Value-Added Tax Act, Article 34(2)1 of the Enforcement Decree of the Value-Added Tax Act, Article 24(1) [Attachment Table 1] subparagraph 12(5) [Attachment Table 1] of the Enforcement Rule of the Value-Added Tax Act (hereinafter “instant provision”) by January 2013 pursuant to Article 12(1)1 of the former Value-Added Tax Act (amended by Act No. 11873, Jun. 7, 2013); Article 24(1)1 of the former Enforcement Decree of the Value-Added Tax Act (amended by Ordinance of the Ministry of Strategy and Finance No. 251, Jun. 28, 2013)

It shall be determined based on current laws and regulations.

The Plaintiff’s request for correction was rejected on the ground that it is not subject to value-added tax exemption (hereinafter “each disposition of this case”).

C. On May 24, 2018, the Plaintiff filed a tax appeal on each of the instant dispositions, but was dismissed on April 18, 2019.

[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 1, 2 and 3 (if available, including branch numbers; hereinafter the same shall apply) and all pleadings.