A. On April 10, 200, the Plaintiff was a company engaged in value-added telecommunications business and registered its business with its principal place of business.

B. On May 31, 2014, the Plaintiff entered into a logistics agency agreement with the Korea Transportation Corporation, which provides that all logistics-related services such as the storage, delivery, and storage of goods, at the logistics center located at 46 Doo-ro 904, as the 00-ro death of the wife population, on behalf of the Plaintiff.

C. On December 7, 2015, the Plaintiff registered its business with respect to the above logistics center (hereinafter “instant place of business”), and on January 1, 2016, converted into a business unit taxable business under Article 8(3) of the Value-Added Tax Act.

Upon filing the final return of value-added tax on January 5, 2016, the Plaintiff filed the final return of value-added tax on the second period (from July 1 to December 31, 2015) in 2015, and filed the return by deducting KRW 123,956,102, the amount of tax on KRW 1,239,56,56,064, which is the balance in the settlement of service fees incurred from June 1, 2015 to November 30, 2015 in relation to the said contract, as the input tax amount of the instant workplace.

Accordingly, the output tax amount reported by the Plaintiff is KRW 149,366,553, and the input tax amount is KRW 319,860,484 (the input tax amount is KRW 123,956,102, other input tax amount is KRW 195,904,382). The refundable tax amount based on the Plaintiff’s declaration is KRW 170,493,93,931 (the sales tax amount is KRW 149,36,53 - the input tax amount is KRW 319,860,484, not KRW 170,493,931, but KRW 170,503,931,000). The Defendant decided that the above adjusted the input tax amount from the head office other than the instant head office on March 28, 2016 to KRW 123,96,196, and the Defendant did not deduct the said input tax amount from the instant input tax amount from KRW 36315,506,296.