부가가치세부과처분취소
1. On September 4, 2012, the director of the tax office having jurisdiction over the Plaintiff on September 4, 2007, the value-added tax amounting to KRW 767,026,750, and February 2, 2007.
1. Details of the disposition;
A. The Plaintiff is a corporation that runs the business of manufacturing white compound.
Plaintiff
C, the representative director of B, on October 12, 2004, registered a business operator of gold wholesale business with the trade name "D," but closed on April 6, 2009.
The sum of the supply value of the tax invoices for the taxable period of 1st 3,758,277,231 207 2,130,030,567 2,208 2,130,567 2,75,725,780,390,390 for the second period of 2nd 1,362,319,835 207
B. During the taxable period from January 2007 to February 2, 2008, the Plaintiff received purchase tax invoices of KRW 7,725,780,420 (hereinafter “instant tax invoice”) from D, as indicated below, and paid the value-added tax by deducting the relevant input tax amount from the output tax amount when filing a value-added tax return for each of the said taxable periods.
C. From April 5, 2012 to June 5, 2012, the director of the Central Regional Tax Office: (a) determined that “D cannot be deemed to fall under a business establishment established by the Plaintiff for the purpose of receiving purchase data, and thus, constitutes a false tax invoice different from that of a supplier; and (b) notified the Defendants of the aforementioned taxation data.”
Accordingly, on September 3, 2012, the head of the Chungcheong District Tax Office notified the Plaintiff of the rectification of KRW 44,902,120 for the value-added tax of 208, which was 208, and on September 4, 2012, the head of the competent tax office issued the Defendant Notice of the Correction of KRW 767,026,750 for the value-added tax of 1, 2007, KRW 270,515,480 for the value-added tax of 2,07, KRW 411,329,90 for the value-added tax of 2,208, KRW 44,210,00 for the value-added tax of 2,208, KRW 97,325,580 for the corporate tax of 207, KRW 5163,070 for the corporate tax of 208 (hereinafter collectively referred to as the “instant disposition”).
E. The Plaintiff, who is dissatisfied with the instant disposition, filed a request for review with the Board of Audit and Inspection on October 12, 2012.