2. The costs of lawsuit shall be borne by the Plaintiff.

A. The Plaintiff is a clothing manufacturing and wholesale retail company, and the head of the Incheon customs office, upon conducting a customs investigation on the Plaintiff around September 2013, deemed that the Plaintiff was directly engaged in all customs duties with respect to the case of importing Korean male clothing in the name of the Jung-gu Commercial Co., Ltd. and the Jung-gu Commercial Co., Ltd. (hereinafter “Seoul Commercial Co., Ltd.”), and determined the importer as the Plaintiff. The Plaintiff revoked the import tax invoice issued to the Il-gu Commercial Co., Ltd. and issued the import tax invoice as shown in attached Table 1 (hereinafter “instant import tax invoice”).

B. Accordingly, on December 18, 2013, the Plaintiff filed a claim for correction of the tax base and tax amount for which refund of the above input tax amount was sought by asserting that the tax base (total amount of KRW 290,120,870) of the import tax invoice of this case was omitted for the taxable period from February 18, 2011 to January 1, 2013, the Plaintiff rejected the Plaintiff’s claim for correction on the ground that the import tax invoice of this case received through the customs investigation by the Plaintiff was not subject to input tax deduction.

(hereinafter referred to as “instant refusal disposition”). C.

On July 11, 2014, the Plaintiff appealed and filed an appeal with the Tax Tribunal, and the Tax Tribunal dismissed the Plaintiff’s appeal on December 16, 2014.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 4, 6, purport of the whole pleadings

2. The Plaintiff’s alleged import tax invoice is a tax invoice issued by the head of Incheon Customs Office to the Plaintiff, a genuine importer, by changing the import entity. The Plaintiff was entitled to receive input tax deduction, since it was not issued a tax invoice identical to the import tax invoice in the first taxable period, and thus, the Plaintiff was entitled to request the refund, and on any other premise.