부가가치세부과처분취소
1. The plaintiff's claims against the defendants are all dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. The Plaintiff, with the trade name of “B”, received a tax invoice related to sales commission of KRW 10,59,87,72,563 (hereinafter “each of the instant tax invoices”) from “C” from “C” during the first period from 1st to 1st of 2014, and from “D”, KRW 2,133,99,99,97 from “D”, KRW 1,633,228,697 from “E”, and KRW 4,035,014,783 from “F”, and KRW 10,59,872,563 from “F” (hereinafter “each of the instant tax invoices”). At the time of each of the instant tax periods, the Plaintiff filed a value-added tax return by deducting the input tax amount under the respective value-added tax invoices from the output tax amount.
In addition, the Plaintiff filed global income tax return from 2011 to 2013 by including the supply value under each of the above tax invoices in the necessary expenses.
B. The director of the Seoul Regional Tax Office, as a result of the tax investigation against the plaintiff, deemed the transaction on each of the tax invoices of this case received by the plaintiff from each of the purchasing agencies of this case as the processing transaction and notified the defendants of
C. On April 2, 2015, the head of Mapo Tax Office deemed that each of the instant tax invoices received from each of the instant buyers constituted false tax invoices, and determined that the Plaintiff’s input tax amount under each of the said tax invoices was non-deductible to be included in KRW 15,058,210 (including additional tax; hereinafter the same shall apply), KRW 189,779,950 of the value-added tax for the second year of 2011, KRW 16,86,130 of the value-added tax for the first year of 2012, KRW 281,429,30 of the value-added tax for the second year of 2012, KRW 254,473,440 of the value-added tax for the first year of 2013, KRW 241, value-added tax for the second year of 204, KRW 450 of the value-added tax for the second year of 2015, KRW 1585.