3. The disposition of imposition of KRW 13,726,680 of corporate tax for the business year 2010 against the Plaintiff and the disposition of imposition of KRW 13,726,680 on July 1, 2016.

A. The Plaintiff is a corporation established on February 26, 2009 for the purpose of steel, steel, steel, and steel wholesale and retail business.

B. The Plaintiff purchased scrap metal from five trading companies, such as A, B, C, D, and E, and deducted the supply value of 6,863,341,820 won from each of the above companies during the business year 2010 (from January 1, 2010 to December 31, 201), and filed a voluntary return and payment of the relevant input tax amount from the output tax amount by voluntarily deducting the supply value of 11,401,120,81, and the supply value of 15,60,14,590 won from the output tax amount for the business year 2012 (from January 1, 201 to December 31, 2012) (hereinafter “instant tax invoice”).

C. However, the director of Busan Regional Tax Office conducted an investigation into the transaction order with the above five trading companies, and as a result, each of the above trading companies constitutes data, the tax invoice of this case received by the Plaintiff from each of the above trading companies was issued differently from the fact, and notified the Defendant of the tax invoice of this case as taxation data.

Around July 15, 2013, the Defendant: (a) deducted input tax amount on the instant tax invoice based on the foregoing taxation data; (b) imposed value-added tax on the Plaintiff; (c) on August 4, 2014, by applying 2010-2012 to the value of supply of the instant tax invoice pursuant to Article 76(5) of the Corporate Tax Act; and (d) imposed tax amount of KRW 677,292,130 (137,26,830 for the business year 2010, KRW 228,02,410 for the business year 228,02,41, KRW 312,02,890 for the business year 2012.

E. After being audited by the Busan Regional Tax Office’s Inspector Office, the Defendant pointed out that “an amount received differently from the fact” under Article 76(5) of the Corporate Tax Act should be imposed additional tax by interpreting the value of supply as the total value of value-added tax, which is the value of supply.”