The judgment below is reversed, and the case is remanded to the Seoul High Court.

The grounds of appeal are examined.

1. Article 54 of the Value-Added Tax Act provides that where an entrepreneur has issued or received tax invoices or revenue invoices, he/she shall submit a list of total tax invoices by customer and a list of total tax invoices by customer (hereinafter “list of total tax invoices by customer”) and a list of total tax invoices by customer (hereinafter “list of total tax invoices by customer”) in which the registration number, name or title, transaction period, date of preparation, total amount of supply price during the transaction period, and total amount of tax amount, and other matters prescribed by the Presidential Decree are entered at the time of filing the pertinent preliminary return or final return. However, if an entrepreneur issues or receives electronic tax invoices and transmits the details of the issuance of tax invoices to the Commissioner of the National Tax Service by the 11th day of the month following the last day of the taxable period (the preliminary return period in cases of preliminary return) in which the relevant goods or services are supplied, the obligation to submit a list

In addition, Article 54(6) of the Value-Added Tax Act and Article 97(2) of the Enforcement Decree of the Value-Added Tax Act provide that the portion of issuing electronic tax invoices transmitted by the 11th day of the following month following the end of the taxable period shall be indicated as the total amount of sales (number of purchase places), total number of purchase, total supply amount, total tax amount (purchase) and total tax amount (purchase) items, on the other hand, in addition to the total amount of tax invoices issued for the portion of issuing the tax invoices, the business registration number, trade name (name of corporation), purchase, supply value, and tax amount shall be written as the item of items by sales place (by seller).

One electronic tax invoice system is the cost of tax payment cooperation and the administrative cost of the tax authorities that arise excessively in connection with the tax invoice.