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(영문) 서울행정법원 2017.11.02 2015구합58034

부가가치세등부과처분취소

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1. The plaintiff's claim is dismissed.

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

Reasons

1. Details of the disposition;

A. The Plaintiff is a corporation established on March 24, 200 for the purpose of the distribution of a distribution monitoring system, various measuring instruments retail business, software development-related business, and software package development-sale and lease business.

The supply value in the taxable period at the purchase place (won) C Co., Ltd. 2, 2008 2,285,52,000 2,200 663,100,000 2,209 876,677,670,000 2,702,666,00 2,200 2,50,380,000 2,208 2,620,620,000,000 23,20,000,000 68,000,000,000 small 2,00,200,2333,000,003,0036,76,707,2006,300,0003 D 2012,67,630,700,000

B. The Plaintiff received each purchase tax invoice of KRW 2,702,66,000, total supply value of KRW 233,000,000 in each taxable period of value-added tax from February 2, 2008 to January 1, 2010 from Co., Ltd. (hereinafter collectively referred to as “purchase tax invoice of this case”) in each taxable period of value-added tax from February 2, 2008 to February 2, 2009 from Co., Ltd. (hereinafter collectively referred to as “the purchase tax invoice of this case”).

C. The Plaintiff, as listed in the table below, issued to C each sales tax invoice of KRW 20,90,760, total value of supply in each taxable period from February 2, 2008 to January 2010, including KRW 820,903,760, ② to E, a stock company, KRW 377,312,00, and KRW 377,300,000, total value of supply in each taxable period from January 2, 2009 to January 1, 2010 (hereinafter collectively referred to as “instant sales tax invoice”; and collectively, to F, each sales tax invoice of KRW 277,40,000, total value of supply in each taxable period from value-added tax for the second taxable period from 2011 (hereinafter collectively referred to as “instant sales tax invoice”).

C Co., Ltd. 106,661,000 on February 2, 2008, 2009 292,616,000.