1. The Defendant’s imposition of value-added tax of KRW 59,889,160 on December 2, 2013 against the Plaintiff on December 2, 2013, 50,000, respectively.

1. Details of the disposition;

A. The Plaintiff is a company established on May 22, 2009 and engaged in the wholesale and retail and scrap metal processing business, etc. of steel products, and the Plaintiff constitutes so-called “old field company,” which purchased scrap metal, etc. and supplies them to Hyundai Steel Co., Ltd. (hereinafter “Modern iron”).

The amount (value of supply, unit) to be received for the year to which the status of the purchaser belongs (value of supply, unit): B B representative of the second period 1,135,588,440 AD 2011 and 64,580,900 D 1, 2011, 2012, 1,190,738,760,760 E 1, 4039,930 E 1, 2011, 257,750,60,680 GH 2,2,067,093,090 GH 2,12,18,514,820,820, 201, 2011, 36,535, 680 GH 20 G 20, 2011, 12,514, 8208, 1948, 2984

B. During the taxable period from the first half to the first half of the year 2012, the Plaintiff received a tax invoice equivalent to the total supply value of KRW 8,498,104,710 in the name of six enterprises including A, as follows. Based on this, the Plaintiff filed a value-added tax return by deducting the relevant input tax amount from the output tax amount.

C. On September 1, 2012, the Defendant denied the input tax deduction under the tax invoice under B, and notified the Plaintiff of the rectification of KRW 188,540,510 (including additional taxes) of the value-added tax for the second period of value-added tax in 2011.

(hereinafter “previous Disposition”). Although the Plaintiff filed an administrative litigation seeking the revocation of the previous disposition, the Plaintiff was dismissed in the Daejeon District Court Decision 2013Guhap2732 on July 17, 2014, which became final and conclusive on April 15, 2015.

In addition, the Defendant conducted a tax investigation with the Plaintiff from September 5, 2013 to September 24, 2013, determined that the tax invoice issued by the Plaintiff in the name of A, E, G, I, and K (hereinafter “instant purchase contract”) constitutes a false tax invoice that is issued without a real transaction.

Accordingly, the Defendant denied the deduction of input tax pursuant to the instant tax invoice, and on December 2, 2013, the amount of value-added tax for the first term of December 2, 2011 to the Plaintiff is KRW 59,889,160 (including additional tax) and the second term of December 2011.