A. On December 1, 201, the Plaintiff: (a) was a corporation engaged in the business of wholesale business of non-ferrous metals from YY-gun, Gyeonggi-gun; (b) was issued 33 copies of purchase tax invoices amounting to KRW 4,667,00,000 (hereinafter “instant transaction”); and (c) deducted the said input tax amount from the output tax amount, and filed a return and payment of value-added tax by deducting the said input tax amount from the output tax amount.

B. The director of the Central Regional Tax Office, upon conducting a tax investigation against A, confirmed the instant transaction as a processing transaction and notified the Defendant. The Defendant considers the instant tax invoice as a false tax invoice without real transaction and deducts the relevant input tax amount when calculating the value-added tax, and then, deducted the relevant input tax amount.

2. 14. The Plaintiff corrected and notified each of the Plaintiff the value-added tax of KRW 304,104,299, value-added tax of KRW 504,490,838 for the second term of 2012, and KRW 1,363,96,00 for the corporate tax of KRW 1,363,96,00 for the year 2012.

(hereinafter referred to as “instant disposition”) imposition of value-added tax for the first and second period of January 2012.

On March 5, 2015, the Plaintiff filed an appeal with the Tax Tribunal. On March 5, 2015, the Tax Tribunal issued an order to correct the amount of tax on corporate tax and dismissed the decision on the imposition of value-added tax.

[Reasons for Recognition] Uncontentious Facts, Gap evidence 1, Eul evidence 1 and 2, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion is not a false or processed tax invoice on the ground that the Plaintiff was actually supplied by A with the closure corresponding to the value of supply stated in the instant tax invoice.

Therefore, the instant disposition is unlawful on a different premise.

(b) as shown in the attached Form of the relevant statutes;

(c).