1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The purport of the claim and appeal is the purport of the appeal.

The reasoning of the judgment of this court citing the judgment of the court of first instance is as stated in the reasoning of the judgment of the court of first instance, except for the addition of the following judgments as to the allegations added by the plaintiff in this court, and thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and Article

Additional Judgment

A. The Plaintiff asserts that the imposition of additional tax due to the failure to submit a list of total tax invoices in the instant disposition was unlawful, since all the second list of total tax invoices was submitted to the Defendant in 2012.

In full view of the overall purport of the pleadings in the statement No. 28-1 and No. 28-1 and No. 1, the Plaintiff submitted to the Defendant a list of total tax invoices by seller during the second period of 2012, which was entered as the purchaser price of KRW 5,150,000,000 for supply price C. The Defendant, as seen earlier, is difficult to deem that C did not issue a tax invoice to the Plaintiff in connection with the instant contract and issued a tax invoice to the Plaintiff in error. However, on the ground that the Plaintiff submitted a list of total tax invoices by seller, the Plaintiff submitted the list of total tax invoices by seller, which was entered as the purchaser price C, including imposition of penalty tax of KRW 50,00,00,00.

According to Article 22(5)3 of the former Value-Added Tax Act, in cases where the supply value in the entry of a list of total tax invoices by seller is excessively entered and returned differently from the fact, an additional tax amount equivalent to 1/100 of the reported supply value shall be imposed. Thus, it is lawful for the Defendant to impose an additional tax as above.

The plaintiff's above assertion is without merit.

B. In addition, the Plaintiff’s amendment of the former Value-Added Tax Act and the Enforcement Decree mitigated regulation on the tax invoice, C paid all the output tax amount related to the instant contract, and B did not file any tax return in relation to the instant contract.