1. The Defendant’s imposition of value-added tax on April 3, 2012 against the Plaintiff for the first period of 2010 KRW 32,573,818.

1. Details of the disposition;

A. From April 5, 2006, the Plaintiff is a corporation that runs a construction business and a wholesale and retail business in the legal principle of Eup in the court of Pakistan-si from April 5, 2006.

B. The Plaintiff received the purchase tax invoice of KRW 407,061,00 (hereinafter “instant tax invoice”) from A (hereinafter “A”) in the first taxable period of value added tax (hereinafter “instant taxable period”) in 2010, and completed the first taxable period of value added tax for 2010 after deducting the relevant input tax amount from the output tax amount.

C. From June 16, 2010 to November 22, 2010, the head of the provincial tax office conducted a survey on data with A, and subsequently confirmed the total amount of sales tax invoices issued by A for 104 companies during the 2009 taxable period of the value-added tax for the second taxable period of the value-added tax in 2009 to the first taxable period of the value-added tax, and the instant tax invoice was also included in the said subject matter.

On April 3, 2012, the Defendant notified the Plaintiff of the foregoing contents as taxation data, determined that the instant tax invoice constitutes a tax invoice written differently from the fact, and subsequently, notified the Plaintiff of the correction of the value-added tax amounting to KRW 72,261,460 (including additional tax) for the first time, which was the first time tax invoice in 2010.

E. Meanwhile, on May 1, 2013, when the instant lawsuit was pending, the Defendant corrected the imposition of value-added tax of KRW 72,261,460 to the effect that the penalty tax of KRW 32,573,818 is to be reduced (hereinafter “instant disposition”). On the same day, the Defendant notified the Plaintiff of an advance notice of penalty tax as to the principal tax of value-added tax of KRW 72,261,460, stating the type of penalty tax and the grounds for calculation, etc.

[Reasons for Recognition] Facts without dispute, entry of Eul Nos. 1, 2, 5, and 6 (including each number), the purport of the whole pleadings

2. Whether the part seeking revocation of penalty taxes among the instant lawsuit is lawful.