법인세등부과처분취소
1. All of the plaintiff's claims are dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. The Plaintiff is a company established on July 30, 200 for the purpose of manufacturing and selling clothing, internal clothing, and sheep, and a company that sells home shopping, online store, or off-line store with the trademark attached B and C.
B. From around 2010, the Plaintiff was produced by a company located in the Chinese Republic of China (hereinafter “China Production Company”) from D, and was supplied with clothes for which an import declaration was filed under D’s name and sold in Korea.
The Plaintiff received a tax invoice issued D (hereinafter “instant tax invoice”) in the taxable period of value-added tax from February 2, 2010 to February 2, 2012, and declared the input tax amount under the said tax invoice after deducting the input tax amount from the output tax amount at the time of filing the return of value-added tax for
C. When filing a report on corporate tax for the business year 2010 to 2012, the Plaintiff included the amount of money paid as raw material as deductible expenses in the pertinent business year to E, D, F, G, H, and I (hereinafter collectively referred to as “Plaintiff’s customer”).
After conducting an integrated tax investigation against the Plaintiff, the Central Regional Tax Office: (a) conducted a corporate tax investigation against the Plaintiff; (b) provided the Plaintiff with actual suspicions to China rather than D; (c) so, the instant tax invoice was written differently from the fact that the Plaintiff is a false tax invoice; and (b) received the amount equivalent to or part of the amount of the raw materials from the Plaintiff’s transaction partner, who was returned from the Plaintiff’s transaction partner, to the account held in the name of the Plaintiff’s director (hereinafter “the instant price”), but did not actually receive the amount of raw materials (hereinafter “the instant price”), but received a disguised payment or a refund of the difference after paying the amount of raw materials so returned. As such, the instant tax invoice was notified of the taxation data, which is the processing cost, respectively.
(e) Accordingly.