부가가치세부과처분취소
1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. On March 15, 2012, the Plaintiff is a business entity that operates bathing materials and stone wholesale and retail business with the trade name “C” in the Seosung City B.
The Plaintiff received four items of purchase tax invoices of KRW 70,59,09,00 for KRW 15,498,181, KRW 27,272,727 in 2014, and KRW 37,559,090 in 2015, and filed a value-added tax return after deducting the input tax amount for the pertinent taxable period from the purchase tax invoices of KRW 70,329,998 in 2014.
B. From November 7, 2016 to January 1, 2017, the Central Regional Tax Office conducted an investigation into value-added tax with respect to the value-added tax for the period from 1, 2014 to 2, 2015 of the purchase price of this case, it confirmed that the purchase price of this case issued approximately KRW 6 billion to 105 business operators including the Plaintiff, and notified the Defendant of the taxation data regarding the fact that the Plaintiff received KRW 70,329,998 from the purchase price of this case constitutes a processed tax invoice.
C. Based on the information notified, the Defendant did not deduct the input tax amount deducted for the tax invoice received by the Plaintiff from the instant purchaser. On November 1, 2017, the Defendant issued a revised notice of KRW 5,165,474, and KRW 6,353,685, which was 2014 to the Plaintiff on November 1, 2014.
On January 18, 2018, the Plaintiff filed an objection with the Defendant. On January 18, 2018, the Plaintiff’s first purchase in 2014, and KRW 17,989,091 out of the second purchase in 2014, were deemed to be a real transaction, and thus the first value-added tax was revoked on April 6, 2018, and the second value-added tax in 2014 was re-revision to reduce the amount of KRW 3,407,134.
However, a tax invoice amounting to KRW 46,842,726 in total amount of KRW 31,98,500 for the first purchase in 2015, among the second purchase in 2014 (hereinafter collectively referred to as “instant tax invoice”) was not recognized as a real transaction.
[Attachment 1,758,340 won (=5,165,474 won - 3,407) for the imposition of value-added tax for the second period of 2014 reduced (hereinafter referred to as "reduction 2014").