1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. As stated in the purport of the claim, the Plaintiff sought revocation of the part exceeding one million won among the disposition of this case’s corporate tax and the part exceeding seven thousand,117,500 won among the disposition of this case’s additional tax. The court of first instance dismissed the claim seeking revocation of the general underreported additional tax amounting to KRW 4,500,000 among the disposition of this case’s additional tax, etc., and accepted all the remaining claims.

Since the defendant appealed only, the scope of the judgment of this court is limited to the portion exceeding one million won among the disposition of this case, and the portion exceeding seven thousand,17,500 won, excluding the claim for revocation of the general underreporting penalty tax amounting to 4,500,000 among the disposition of this case, including the surcharge of this case.

2. Details of the disposition;

A. The Plaintiff purchased B from Company B (hereinafter “B”) during the first value-added tax period in 2011, and received seven copies of the purchase tax invoice for KRW 2.425 billion (hereinafter “instant tax invoice”), and sold B on the upper metal (hereinafter “daily metal”), and issued three copies of the purchase tax invoice for KRW 2,7220,000 during the first value-added tax period in 201, and one copy of the purchase tax invoice for KRW 35,874,00,000 in the supply price for the second value-added tax period in 2011, and reported and paid to the Defendant each of the above supply value including the output tax amount and the value-added tax calculated including the input tax amount.

B. From September 11, 2012 to April 26, 2013, the director of the Central District Tax Office: (a) conducted an investigation on B with respect to B; (b) determined B as a so-called data or conduit company that issues a tax invoice without actual transaction; (c) notified the Defendant; (d) the director of the Seoincheon District Tax Office also conducted an investigation on the commercial metal from November 24, 2012 to January 25, 2013; and (c) determined that the purchase tax invoice issued by the Plaintiff to the upper metal is false; and (d) notified the Defendant thereof.