부가가치세 및 법인세 부과처분취소
1. The Defendant’s value-added tax for the Plaintiff on October 1, 2014, KRW 177,647,640, and KRW 2012, which was assessed against the Plaintiff on October 1, 2012.
1. Details of the disposition;
A. From December 29, 2005, the Plaintiff is a legal entity that runs a non-ferrous metal wholesale business in Silung-si B.
B. The Plaintiff received a tax invoice of KRW 6,423,100,000 (hereinafter “each of the instant tax invoices”) from Company C, Company D, Company E, Company E, Company F (hereinafter “C”, “D”, “E”, and “F” for the period from the first taxable period of value added tax in 2012 to the first taxable period of value added tax in 2013 (hereinafter “the instant tax invoices”), as indicated in the following table, and filed a tax invoice of KRW 6,423,100,000 (hereinafter “each of the instant tax invoices”) by deducting the input tax amount from the output tax amount for the period from the output tax period in 2012 to the first taxable period of value added tax in 2013, and filed a tax return and payment on corporate tax for each business year in 2012 and
The purchase amount (supply price) at the first half-year 2012 for the first half-year 2013 - C- 893,986,000 4,104,539,00 4,998,525,000 D 472,092,092,000 323,116,000 130,919,000 926,127,000 E 269,35,35,000 F29,000 for the second half-year 269,35,000 for the first half-year 229,000 for 229,229,000-29,000-29,00,229,093,000, 970,217, 102,004,520,304,205
C. As a result of an investigation conducted with respect to the transaction order of the tax invoice against the Plaintiff, the Defendant: (a) deemed each of the tax invoices of this case as false data; and (b) deducted the input tax amount under each of the tax invoices of this case; (c) on October 1, 2014, the Defendant issued a revised notice of KRW 17,647,640 for the Plaintiff on October 1, 2012, of KRW 216,059,940 for the value-added tax of KRW 2,200 for the year 2012; (d) KRW 48,128,120 for the corporate tax of KRW 48,128,120 for the year 2012; and (e) KRW 728,879,960 for the value-added tax
(hereinafter “instant disposition”) D.
On January 9, 2015, the Plaintiff appealed to the Tax Tribunal, but the Tax Tribunal dismissed the request on December 31, 2015.
[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 3, 4, Eul evidence Nos. 1 and 2, the purport of the whole pleadings
2. Whether the instant disposition is lawful
A. The plaintiff's assertion ①