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. Details of the disposition;

A. The Plaintiff is a company established on February 7, 201 and engaged in the business of refining, refining, refining, and reprocessing of non-metallic metals in 161-26, 161-26, Jinsan-si, Jinsan-si, Busan-si.

The aggregate of the supply value of the product quantity on the date of supply by the sequence 7,320 g 61,927,200 g 61,927,720 g 6,19,920 g 68,119,920 g 10,580 g 79,350,000 g 7,935,935,000 g 87,285,277,200 g 14,125,720 g 15,404,920 won on May 9, 2012

B. The Plaintiff received two tax invoices consisting of the total supply value of 155,404,920 (hereinafter referred to as “instant tax invoices”) from Company A (hereinafter referred to as “A”), in sequence, each of the instant tax invoices was deducted from the output tax amount, and filed a return and payment of the value-added tax for 1 year 2012, by deducting each of the instant tax invoices from the output tax amount.

C. From September 6, 2012 to January 31, 2013, the director of the Central District Tax Office: (a) conducted a tax investigation with respect to A; (b) issued processed tax invoices of KRW 20,442,71,340 to 18 companies, including the Plaintiff, without real transaction during the first taxable period of the value-added tax in 2012; and (c) received processed tax invoices of KRW 20,246,474,630 (hereinafter “the so-called “data”), and (d) notified the Defendant of the taxation data by deeming that each of the instant tax invoices constituted a disguised processing tax invoice.

Accordingly, the Defendant did not deduct the relevant input tax amount from the output tax amount on the ground that each of the instant tax invoices received from A constitutes a tax invoice different from the facts, since the Defendant constitutes a data that the Plaintiff issued a false tax invoice without real transactions. On January 6, 2014, the Defendant corrected and notified the Plaintiff on January 1, 2012 value-added tax amounting to 24,685,040 (hereinafter “instant disposition”).

E. The Plaintiff appealed and filed an appeal with the Tax Tribunal on April 2, 2014. However, the Plaintiff’s claim on November 2, 2014.