부가가치세등부과처분취소
1. On September 2, 2014, the Defendant imposed the Plaintiff KRW 2,626,058,967 on September 2, 2012.
1. Details of the disposition;
A. On May 1, 2015, the Plaintiff was a company that is a self-subsidiary of lsls (hereinafter “lsls”) and was engaged in manufacturing and selling non-ferrous metal recycling materials, etc., and was merged with Lls Korea Co., Ltd., a subsidiary of lsls (hereinafter “ls”) as in the Plaintiff on May 1, 2015.
(hereinafter referred to as “Plaintiffs” without distinguishing the Plaintiff from Sax Korea Co., Ltd.
In the process of purchasing ice rap supplied to lss (hereinafter “instant tax invoice”), the Plaintiff received a tax invoice equivalent to KRW 6,096,64,120 from A and B (hereinafter “instant transaction party”) during the 2nd taxable period of value-added tax in 2011 from the 2nd taxable period of value-added tax in 201 to the 2nd taxable period of value-added tax in 2012 (hereinafter “the instant transaction party”), and then filed a tax invoice equivalent to KRW 1,080,41,40 in the value-added tax taxable period of the 1st taxable period of value-added tax in 2012, and filed a tax invoice equivalent to KRW 6,096,64,120 in the 2nd taxable period of value-added tax in 2012 (hereinafter “instant tax invoice”). The Plaintiff
C. The Defendant: “The Plaintiff, in fact, purchased ice rap from another supplier, who is not the transaction partner of the instant case; and, on the ground that the instant tax invoice is false, deducted each of the above input tax amounts under the instant tax invoice, and notified the Plaintiff of the correction and notification of each of the value-added tax (this tax, penalty tax, and penalty tax) and corporate tax (additional tax) as stated in the separate sheet [14.9.2].
(hereinafter) Each of the above value-added taxes and the disposition of correction and notification of corporate tax are referred to as “each of the instant dispositions”).
On December 1, 2014, the Plaintiff, who was dissatisfied with each of the instant dispositions, filed a petition for an inquiry with the Tax Tribunal, but was dismissed on October 7, 2015.
[Reasons for Recognition] A. Each entry in Gap evidence Nos. 1, 2, and 97 (including paper numbers; hereinafter the same shall apply), pleading.