2. The costs of lawsuit shall be borne by the Plaintiff.

A. The Plaintiff is a corporation established on October 12, 2010 for the purpose of trade business, manufacture and sale of clothing, etc., and engaged in the business of producing raw materials necessary for the manufacture of clothing and exporting it to a foreign country, and B (hereinafter “B”) is a corporation established on January 5, 1994 for the purpose of trade business, manufacture and sale of clothing, etc., and is engaged in the business of exporting clothing after being supplied with raw materials from the Plaintiff.

B. From January 7, 2015 to March 23, 2015, the Seoul Regional Tax Office determined that the result of the integrated investigation of corporate tax of the Plaintiff and B, and that the Plaintiff directly exported to Indonesia Corporation C (hereinafter “C”) even though the Plaintiff actually supplied the original group to B, and that the transaction relationship was disguised.

Accordingly, as seen in the former Value-Added Tax Act (amended by Act No. 12851, Dec. 23, 2014) on April 1, 2015, the Seoul Regional Tax Office revised the disposition of this case based on the Value-Added Tax Act applicable to each taxable period of each taxable period, although there is a little difference in the legal content applicable to determining the issues of this case, as the difference in the legal content applicable to determining the issues of this case is not significant, it is arranged based on the value-added tax law applicable to the last taxable period (1st

Article 21 of this Act and Article 31(2)1 of the former Enforcement Decree of the Value-Added Tax Act (amended by Presidential Decree No. 25945, Dec. 30, 2014) have not been supplied through a local letter of credit or a purchase confirmation prescribed by Ordinance of the Ministry of Strategy and Finance. Therefore, the Plaintiff denied the details of the return of the value-added tax reported by the Plaintiff and notified the Defendant of the result of tax investigation that the aggregate of value-added tax (including additional tax), 4,196,245,260 won from January 2012 to January 2014, 2014, 2012, and 175,341,570 won (including additional tax) will be imposed upon the Defendant according to the results of tax investigation.