A. The Plaintiff received a tax invoice of KRW 9,941,964,00 (hereinafter “instant tax invoice”) from C and seven other companies (hereinafter “instant purchaser”) as listed in the table below in the first and second taxable periods of the value added tax in 2011, and filed a return of value-added tax by deducting the input tax amount therefrom from the output tax amount.

과세기간 상호(대표자) 매수 공급가액(천원) 2011년 1기 ㈜C(D) 7 1,534,235 2011년 1기 ㈜E(F) 8 931,236 2011년 1기 ㈜G(H) 3 441,879 2011년 2기 ㈜C(D) 19 3,491,245 2011년 2기 ㈜I(J) 10 1,293,230 2011년 2기 ㈜K(L) 7 1,029,822 2011년 2기 ㈜M(N) 4 497,052 2011년 2기 ㈜O(P) 4 479,736 2011년 2기 ㈜Q(R) 4 243,529 소계 9,941,964

B. However, on March 5, 2014, the Defendant issued a revised notice of KRW 535,650,510, and KRW 1,256,020,020 for the first term of value-added tax for the year 201 pursuant to Articles 16(1), 17(2)2, and 21(1)3, etc. of the former Value-Added Tax Act (amended by Act No. 11129, Dec. 31, 201; hereinafter “former Value-Added Tax Act”), stating that the instant tax invoice constitutes a false tax invoice prepared without a real transaction.

(hereinafter collectively referred to as “instant disposition”). (c)

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on July 29, 2014 after filing an objection on April 18, 2014, but was dismissed on November 24, 2014.

[Ground of recognition] Facts without dispute, Gap evidence 1 and 2, Gap evidence 4-1, 2, Gap evidence 5-1, 2, Eul evidence 1 and 6, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion commences transactions at all times so as to avoid disadvantages due to the Plaintiff’s tax evasion by the purchaser.