부가가치세부과처분취소
1. All of the plaintiffs' claims are dismissed.
2. The costs of lawsuit are assessed against the plaintiffs.
1. Details of the disposition;
A. On June 7, 2013, Plaintiff A purchased KRW 301, 302, 303, 304, 305, and 306 from KRW 2,893, 781,00 in total sales price, and completed the registration of ownership transfer in its name on which Plaintiff A purchased KRW 109, 110 from KRW 681,50,00 in total sales price, and completed the registration of ownership transfer in its name on June 7, 2013, Plaintiff B purchased KRW 10 from KRW 681,50,00 in total sales price.
(hereinafter the plaintiffs purchased the above commercial buildings (hereinafter "the commercial buildings of this case"). B.
Plaintiff
A filed an application for early refund of each value-added tax, on May 31, 2013, with the value of supply 2,893,781,00 won of the tax invoice issued in the name of C when filing the first value-added tax on May 31, 2013 as the input tax amount, and Plaintiff B filed an application for early refund of each value-added tax, with the value of supply 980,760,000 won of the tax invoice issued in the name of C when filing the first value-added tax on
(hereinafter referred to as “each of the instant tax invoices” in addition to each tax invoice issued in C.
However, the Defendant deemed that C had repaid the obligation to pay the construction price to D as the instant commercial buildings, and determined that D supplied not only by C as the supplier of each of the instant tax invoices, but also by D.
Accordingly, the Defendant issued a revised notice of KRW 16,122,100, and KRW 9,807,600 to the Plaintiff, respectively, as the value-added tax for December 16, 2013, on the ground that each of the instant tax invoices was a false tax invoice by the supplier, without deducting the supply value of each of the said tax invoices as an input tax amount, on the ground that it is a false tax invoice by the supplier.
(hereinafter “each disposition of this case”). (c)
The Plaintiffs filed a petition with the Tax Tribunal for the revocation of each of the instant dispositions on July 14, 2014 upon filing an objection on March 3, 2014, but filed a petition for adjudication on July 14, 2015.