법인세등부과처분취소
1. The judgment of the first instance court, including the Plaintiff’s claim extended by this court, shall be modified as follows.
1. The reasons for this case, such as the acceptance of the judgment of the court of first instance, are as follows, and the reasons for the judgment of the court of first instance (including attached Form) are as follows, and thus, they are quoted in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.
The 6th sentence "2010 business year" to the 8th sentence below the third letter box shall be as follows:
The third letter box, "No. 1", "No. 1, 2010, 756, 458, 472 won of corporate tax for the business year 2012, 650,164,050 won of corporate tax for the business year 2013, and 94,806,755 won of corporate tax for the business year 2014, and the third letter box, "No. 1," are "No. 1 and No. 11."
Part 4 17-18 of the first page "as there is no rationality or reliability in the calculation of the market price of the defendant, it cannot be seen as a high-priced purchase, and it shall be deleted."
Part 5. The following shall be added to the first place:
Inasmuch as the tax authorities have the responsibility to assert and prove the market price, there is a lack of proof on the market price that is the basis of high-priced purchase, the Plaintiff cannot be deemed to have purchased 16 items from D as high-priced raw materials, and the selection of comparable companies is also appropriate since the “increased” of the 17th page of the 6th page of “(17) of “The increased.”
The 6th page 17, the 8th page 4-5 (“Plaintiff’s Managing Director F” is respectively dismissed as “I in charge of the Plaintiff’s accounting.”
According to the certificate Nos. 3 and 8, the printing confirmation person is F, a managing director, but the resident registration number or address is not indicated, and the signature of the confirmation person is signed in the name of director treatment I, an agent, and it is difficult to view that F confirmed the contents directly.
Part 7. The following shall be added to Part 19:
1) As to the assertion that a blanket transaction is made, the 8th page 13 is below.