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(영문) 서울행정법원 2019.02.21 2016구합73405

소득금액변동통지처분취소

Text

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 specialized in the expressway and airport road packing construction, and B is a representative director of the plaintiff from July 12, 1997 to the date of July 12, 1997.

B. The Defendant conducted a tax investigation on the Plaintiff’s business year 209 through 2013 (hereinafter “instant business year”), and confirmed that the Plaintiff received the processed purchase tax invoice of KRW 6,024,078,390 (the amount excluded from value added tax; hereinafter “the processed purchase amount”) from 15 companies, including Co., Ltd. (hereinafter “Purchase”) during the instant business year, and included it as construction cost, and did not include the total of KRW 3,335,135,449 (hereinafter “the additional cost”) in the cost of labor cost, wages, etc., and did not include the cost of KRW 3,35,135,49 (hereinafter “the additional cost”) in the account book. The Defendant denied the amount of the processed purchase expense of the instant case, and deemed that the amount of KRW 2,770,740,3310, the amount of bonus income accrued to the Plaintiff for the year 205, 209, 209, 2005.

(A) The amount of bonus disposal (C=A-B) 1,091,040, 300, 931, 931, 193, 193, 070, 150, 230101, 655, 405, 359, 93, 410, 410, 305, 359, 410, 410, 305, 307, 307, 397, 397, 397, 390, 497, 205, 130, 201, 750, 40, 4040, 547, 397, 397, 205, 197, 205, 205, 196, 305, 197, 397, 390 (no disposition)

C. The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal, but was dismissed on June 1, 2016.

[Ground of recognition] There is no dispute.