1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. Details of the disposition;

A. The Plaintiff: (a) purchased tax invoices of KRW 1,135,58,440 (36,942,600 on September 30, 201; (b) 191,597,200 on October 17, 201; (c) 358,047,620 on October 31, 201; (d) 181,806,50,500 on November 15, 201; and (e) 53,047,620 on November 31, 201; and (e) 53,60,60,200 on November 30, 201; and (e) 30,31,305,000 won on the purchase tax invoice; and (e) 30,31,305,000 won on the supply price of each of the instant tax invoices.

B. As a result of the investigation conducted with the above A, the head of the Busan District Tax Office determined that the tax invoice of this case constitutes a false tax invoice issued without actual transaction, and notified the Defendant of this fact.

Accordingly, on September 1, 2012, the Defendant denied the deduction of the input tax amount according to the instant tax invoice, and notified the Plaintiff on September 1, 2012 that the amount of the value-added tax for the second term of 188,549,510 (including the additional tax) and the corporate tax for the business year 22,71,740 (including the additional tax) reverted to the Plaintiff in 2011

(hereinafter “instant disposition”). C.

The Plaintiff appealed and filed a tax appeal on December 10, 2012, but the Tax Tribunal dismissed the Plaintiff’s request on June 24, 2013.

[Ground of recognition] Facts without dispute, Gap evidence 1-1, 2, Gap evidence 2, 3, 8, Eul evidence 1-1, 2, Eul evidence 2 and 5, and the purport of the whole pleadings

2. Determination

A. The Plaintiff asserted that the Plaintiff was not a tax invoice different from the Plaintiff’s assertion 1, and the Plaintiff was supplied with scrap metal from A operated by B, as indicated in the instant tax invoice, and accordingly, received the said tax invoice. Therefore, the instant tax invoice constitutes a different tax invoice from the fact.