1. On May 31, 2016, the Defendant’s rejection disposition against the Plaintiff is revoked.

2...

1. Details of the disposition;

A. From October 10, 2014, the Plaintiff is engaged in wholesale and retail business, such as scrap iron and steel scoops, with the trade name “C” from scood City B.

In relation to the above workplace, the Plaintiff reported and paid the value-added tax for the second term of 2014 and the value-added tax for the first term of 2015 as follows.

(unit: 20,348,8412, 392, 392, 803, 60, 235, 373, 907 21,250,218, 340, 218, 340, 2425, 286, 585 15,025,066, 289,410, 228, 628, 941 payable for the second term portion in 2014, 220,348, 8412, 392, 893, 35, 800, 61, 600, 600, 1,235, 657, 251, 2361, 24636, 265, 294, 26365, 261, 26364

B. As a result of conducting a tax investigation on the Plaintiff’s workplace from around April 2015, the director of the Central District Tax Office confirmed that the Plaintiff issued a false tax invoice without any actual transaction during the second and the first and second taxable periods in 2014, and filed a complaint against the Plaintiff for the violation of the Act on the Aggravated Punishment, etc. of Specific Crimes (issuance of False Tax Invoice) upon cancelling the total amount of KRW 12,353,739,070 from among the tax invoices issued by the Plaintiff and imposing the additional tax for unclear tax.

C. On March 23, 2016, the Plaintiff filed a request with the Defendant to seek a refund of KRW 3,358,598,480 (hereinafter “instant tax amount”) totaling KRW 2,125,025,021,830, and KRW 2,125,021,830 for the second term of value-added tax paid pursuant to the special provision on the payment by purchaser under Article 106-9 of the Restriction of Special Taxation Act, but the Defendant rejected the request on May 31, 2016.

(hereinafter “instant disposition”) D.

On July 11, 2016, the Plaintiff filed an appeal with the Tax Tribunal. However, on November 30, 2016, the Tax Tribunal dismissed the Plaintiff’s appeal on the ground that the actual payer of value-added tax paid by the special case of purchase by purchaser under Article 106-9 of the Restriction of Special Taxation Act was not the Plaintiff but the Plaintiff’s sales (purchase).