부가가치세등부과처분취소
1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. From October 1, 2007, the Plaintiff imported chemical raw materials, such as chemical raw materials, such as chemical agents from the trade name of “B,” or purchased them in the Republic of Korea, and engaged in wholesale business for chemical raw materials supplied to manufacturers of chemical products.
B. From February 2, 2010 to January 201, 201, the Plaintiff received purchase tax invoices of KRW 2,417,870,00,00 from C Co., Ltd. (hereinafter “C”), as listed in the following table, and issued sales tax invoices of KRW 2,451,186,00 in total of the supply values as listed in the following table to D (hereinafter “D”) from February 2, 2010 to February 2, 2011, and filed a return on and pay value-added tax by including the supply value of the instant tax invoice in the input tax amount and output tax amount for each taxable period (hereinafter “instant tax invoice”).
(Unit: 1,511,430 1,151,62,62,5731,014,045 1,405 1,405 1,115,415,450 90,6497,64 97,084 517,1351,711 568,82424 December 2012, 20112,020,02892,031,031,031,031,070,870241,6572,657,657,547,415,4165,4165,965,9616, 202, 200,002,031,031,070241,787,659,57,4165,296,416
C. From June 14, 2013 to June 6, 2014, the Commissioner of the Busan Regional Tax Office conducted a tax investigation with respect to C and D, and deemed that the Plaintiff involved in the processing transaction between C and D, and notified the Defendant of the taxation data related to the Plaintiff.
From August 12, 2015 to October 30, 2015, the Defendant conducted an investigation into value-added tax on the Plaintiff. On December 1, 2015, the Defendant notified the Plaintiff of KRW 146,106,897, and the Plaintiff of KRW 101,185,747, regarding the instant tax invoice as the processing tax invoice.
(hereinafter “instant disposition”) D.
On December 30, 2015, the Plaintiff raised an objection against the instant disposition against the Defendant.