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. The Plaintiff is a company established on August 22, 2007 for the purpose of service contract, human resources supply, employment mediation, etc.
The amount (value of supply, unit: Won) received for the year to which the status of the purchaser is reverted, (value of supply, unit: Won) representative, BF 279,276,50 C G 222,567,500 DH 1st 475,521,590 E 2013 1st 3,240,000 total, 980,605,590
B. During the taxable period from the first half to the first half of 2012, the Plaintiff issued a tax invoice equivalent to the total value of KRW 980,605,590 from B, C, D (hereinafter “D”) and E (hereinafter “E”) as follows. Based on this, the Plaintiff filed a value-added tax return after deducting the relevant input tax amount from the output tax amount.
C. From October 31, 2013 to November 19, 2013, the Daejeon District Tax Office conducted a tax investigation with respect to the Plaintiff, and determined that the tax invoice issued by the Plaintiff under the name of the purchaser of the instant case (hereinafter “instant tax invoice”) was a false tax invoice different from the actual fact of transaction.
On February 5, 2014, the head of the Seo-gu Daejeon District Tax Office denied the deduction of the input tax amount under the instant tax invoice, and notified the Plaintiff of the correction of KRW 49,342,570 for the first year value-added tax, KRW 38,094,650 for the second year value-added tax in 2012, and KRW 79,345,150 for the first year value-added tax in 2013.
(hereinafter referred to as the "instant disposition") d. of each of the above dispositions
On April 7, 2014, the director of the Seo-gu Daejeon District Tax Office's authority to impose value-added tax on business operators located in Seo-gu Daejeon Metropolitan City was succeeded to the defendant.
E. On April 30, 2014, the Plaintiff filed an objection against the instant disposition with the Director of the Daejeon Regional Tax Office, but the said application was dismissed on May 28, 2014. On August 13, 2014, the Plaintiff filed an appeal with the Director of the Tax Tribunal for adjudication on August 13, 2014, but the said request was dismissed on May 26, 2015.
[Ground of Recognition] Unsatisfy, Gap evidence 1, 2, Gap.