1. On December 4, 2013, the Plaintiff’s conjunctive claim seeking revocation of the imposition of value-added tax as of December 4, 2013.

1. Details of the disposition;

A. The Plaintiff is engaged in the scrap metal wholesale and retail business with the trade name, “the Hanyang original source point of a stock company,” located in the 753 “Seoul Hayang-gun, Gyeongyang-gun, Gyeongyang-gun.”

B. The Plaintiff received a purchase tax invoice of KRW 1,078,239,170 for supply price in the first taxable period of 2012 and KRW 1,807,493,270 for the second taxable period of 2012 from A, B, and C (hereinafter “the instant transaction party”), and filed a value-added tax return after deducting the said input tax amount from the output tax amount, during the second taxable period of 2012 (hereinafter “instant tax invoice”).

C. After conducting a tax investigation on the Plaintiff, the Defendant: (a) deemed the instant tax invoice as the processed tax invoice; and (b) rendered a disposition imposing value-added tax amounting to KRW 188,594,790 for the first period of December 4, 2012; and (c) imposed value-added tax amounting to KRW 123,528,330 for the second period of December 2012, 2012 on the Plaintiff.

(hereinafter “instant disposition”) D.

On June 30, 2015, the Plaintiff was issued a non-prosecution disposition by the head of the original District Prosecutors' Office, which was against the charge of violating the Punishment of Tax Evaders Act, with respect to the charges of violating the Punishment of Tax Evaders Act, on August 27, 2015, and then requested the Defendant to rectify the instant disposition on August 27, 2015, but the Defendant rejected it on October 5, 2015.

(hereinafter “Disposition Rejecting Correction of this case”). (e)

The Plaintiff filed an objection against the Defendant on November 20, 2015, but was dismissed on December 15, 2015, and filed a request for examination with the Commissioner of the National Tax Service on March 11, 2016, but was dismissed on April 28, 2016.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, 4, Eul evidence 1 to 3 (including branch numbers; hereinafter the same shall apply), the purport of the whole pleadings

2. The attachment to the relevant Acts and subordinate statutes shall be as follows;

3. Judgment on the main claim

A. The Plaintiff’s assertion was issued the instant tax invoice according to the actual transaction with the transaction partner of the instant case, and against the Plaintiff.