A. On July 1, 2009, the Plaintiff was established and operated a soft business related to electronic commerce and electronic commerce, and received 9 copies of the purchase tax invoice 9 (the total supply price of KRW 8,200,598,264; hereinafter “the purchase tax invoice of this case”) from the Small and Medium Business Distribution Center (hereinafter “Small and Medium Business Distribution Center”) during the period of 1 and 2010, and issued and issued 9 copies of the sales tax invoice 9 (the total supply price of KRW 8,322,68,855; hereinafter “the sales tax invoice of this case”) to A (hereinafter “A”).

(1) On March 31, 2010, 220, 20, 20, 20, 30, 48. 3. 8. 1, 20, 46. 3. 8. 1, 20, 46. 3. 8. 6. 1, 30, 46. 8. 3, 46. 8. 1, 20, 46. 3, 46. 1, 46. 3, 171, 45, 453, 97 8. 4. 1, 46. 8, 46. 1, 208; 16. 3. 4. 6. 8, 16. 3, 206

B. From May 17, 2011 to August 24, 2011, the head of the Seoul Regional Tax Office investigated the value-added tax on the Plaintiff and related enterprises, etc., and notified the Defendant of the tax data by deeming the purchase and sale tax invoice of the instant case as the processing tax invoice.

C. Accordingly, the Defendant determined the purchase and sale tax invoice of this case as different tax invoices from the fact that no real transaction was conducted, and reduced the purchase and sale tax amount. On the other hand, Article 10409 of the former Value-Added Tax Act as to the receipt of the purchase and sale tax invoice of this case.