2. The instant lawsuit shall be dismissed.

3. Of the total litigation costs, 40% is the Plaintiff, and the remainder is the Plaintiff.

A. On December 3, 2012, the Defendant: (a) deemed that the Plaintiff received each tax invoice without real transactions during the second period and the first taxable period in 2010; (b) denied the deduction of the input tax amount based on each tax invoice; (c) accordingly, issued a disposition to rectify the value-added tax and impose penalty tax on the Plaintiff on the following details; (d) on the ground that the Plaintiff did not receive lawful documentary evidence regarding the corresponding amount of each tax invoice, the Defendant imposed the penalty tax amount of KRW 15,258,380 for the year 201, and KRW 12,424,740 for the year 201.

(1) The value-added tax amounting to KRW 160,640,640 and the purchase of KRW 160,640,597,00 and KRW 460,57,700 (total 621,237,000) for each of the purchase of KRW 762,91,91,900 and KRW 76,91,900 for the purchase of KRW 160,640 and KRW 460,597,00 (total 621,237,000) x 62,123,700 (total 621,237,000 x 00 x 0.1) for the processing place of tax invoice x 15,258,380 (=762,919,00 x 02) for the issuance of additional tax for the processing place of tax invoice x 3064,2076

B. The Plaintiff filed a lawsuit with the Busan District Court seeking revocation of each of the above dispositions, but the above court dismissed all of the Plaintiff’s claims on December 18, 2014, on the ground that each of the above dispositions was lawful.

(Judgment of the court of first instance).

The plaintiff appealed against the above judgment of the first instance court. The appellate court recognized that it is a tax invoice without real transaction, but the requirements of the additional tax for underreporting are incomplete in relation to the imposition of the value-added tax, and the additional tax for receiving evidence is levied.