부가가치세등부과처분취소
1. On January 9, 2015, the Defendant limited to the Plaintiff on January 9, 2015, value-added tax for the second period of two years, 2012 (including penalty tax).
1. Details of the disposition;
A. The Plaintiff is an affiliate of C Group, which engages in the development, production, sales, and maintenance and repair of computer programs.
On the date of the contract (2012), the indication of “stock company” is omitted when specifying each of the following companies below the contracting party (stock company).
On December 31, 2012, the terms and conditions of the contract [the contract amount (unit: KRW 1,971,00) and value-added tax not included] the CHH’s HD broadcasting center’s HD broadcasting system establishment and the project management (PM) supply [2,465,00 (=the portion of the establishment of the broadcasting system and 2,402,00 project personnel expenses for the project)] on December 31, 212, D (1971,00 for the HH H HH center’s HD broadcasting system construction services [1,971,00 won for the initial amount of KRW 1,983,000,000 but was reduced as above on March 15, 2013]; supply of GF model (E production) on March 21, 2012 [1,936,200] supply and demand model 30/60/60/412,75/60/60/7
B. On December 2012, 2012, the Plaintiff concluded each of the following services contracts, subcontracts, and goods supply contracts (hereinafter “first services contract, etc.”) (hereinafter “first services contract, etc.”) according to the sequence thereof.
The purpose of each contract is to supply C with the establishment of the HD Broadcasting System by D (the first and second contracts) and to supply G with F products supplied by E (the third and fourth contracts) by the Plaintiff.
C. The Plaintiff issued or received tax invoices as listed below on each contract date.
(hereinafter) According to the sequence, the term “first purchase tax invoice, etc.” or “first sale tax invoice, etc.” means the combination of each of the above purchase sales tax invoices (hereinafter “each of the instant tax invoices”). (Unit: 2012) The date of purchase (the details of the issuance of sales tax invoices) No. 739,500 C No. 1 of December 21, 2112, 212 related to the person who receives the supply value (including value added tax) on the date of sales [the details of the issuance of sales tax invoices] No. 739,500 C No. 1 of December 31, 2112, 2012.