법인세등부과처분취소
1.The judgment of the first instance shall be modified as follows:
(1) As to the Plaintiff on November 1, 2017, the Defendant reverted to the Plaintiff in 2012.
1. The facts below the disposition of this case do not conflict between the parties, or are recognized by comprehensively taking account of the overall purport of the pleadings in each entry of Gap evidence of Nos. 1 to 7, 18, and Eul evidence of No. 1 to 5 (including numbers, if any).
[1] The Plaintiff, a corporation established around June 2004, engaged in the business of importing and selling clothes, etc. However, around June 2010, the Plaintiff’s representative director B introduced K as the Plaintiff’s investment in the I development project in Vietnam-si or the JJ construction project in Yan-si.
B, around July 2010, on behalf of the plaintiff, made an investment agreement on behalf of the plaintiff, K-A company (L), a representative director, and the above businesses.
B paid from October 2010 to K with the Plaintiff’s funds for raising investment funds for the project.
During the Plaintiff’s business year (from January 1, 2012 to December 31, 2012), the Plaintiff’s funds from the Plaintiff’s account to B account (attached Table 1) were deposited as indicated in the Plaintiff’s account “B account” column, and the B paid the Plaintiff the investment fund raising cost, etc. to K as described in [Attachment 1] column.
[Attachment 1] The amount paid on January 2, 2012. 20,000,000.20,000,0005.20,000.10,000,000 won on January 25, 2012. 80,005,00.06,00.0.06,00,005,00.06.0,005,00.6.0,005,00,00.06.0,005,00. 20.6,05,00,000,005,00. 20.12,00,005,005,00. 20,005,06. 20,005,00,000,005,00