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, a corporation whose business is shipbuilding business, etc., issued a certificate of proving that it provides discretionary processing services (hereinafter “instant certificate”), stating that “the supplier provided export goods processing services as stipulated in the main sentence of Article 26(1)2 of the Enforcement Decree of the Value-Added Tax Act,” with respect to each business partner who supplied clinical processing services during the manufacturing process of the Plaintiff’s vessel for export (sorgies, guard boxes, etc.) and the Plaintiff’s business partner filed a declaration of sales applying zero-rate tax, along with the instant certificate, at the time of filing a value-added tax return on the above processing services.

B. On April 2014, the Defendant investigated the details of the value-added tax return by the companies that supplied the services related to special vessels (hereinafter “instant services”) among the Plaintiff’s customers (hereinafter “the instant transaction parties”), and even if the instant transaction parties are not a defense contractor subject to zero-rate tax rate under Article 105(1)1 of the Restriction of Special Taxation Act, the Defendant is also a defense contractor.

After confirming that the value-added tax was reported by applying the zero-rate tax rate as described in Paragraph (1), the transaction parties of this case notified the transaction parties of the revised value-added tax return, and accordingly, the transaction parties of this case (including the closing parties) did not collect each value-added tax specified in the attached Table 1 for the revised tax amount and paid the revised tax

C. On July 22, 2014, the Plaintiff filed a return on and paid the value-added tax by applying the zero-rate tax rate to the supply of the instant service, which is a general taxable transaction, by mistake, to the Defendant, but thereafter, paid the instant transaction parties KRW 8,409,69,694,170 in total amount equivalent to the value-added tax (10%) from January 2, 2009 to February 2, 2013, and filed a claim for correction to the effect that each of the value-added tax indicated in the “amount of request for correction” in the attached Table 1 should be refunded as the input tax amount for