1. The Defendant’s disposition of KRW 108,230,400 imposed on the Plaintiff on November 3, 2014 shall be revoked.

2...

1. On November 3, 2014, the Defendant issued a tax invoice issued by the Plaintiff (representative C) on March 3, 2010 (hereinafter “instant tax invoice”) to the Plaintiff, and the Plaintiff’s tax invoice issued on March 3, 2010 (hereinafter “instant tax invoice”) is a false tax invoice, and the Plaintiff deemed the amount of input tax deducted based on the said tax invoice as an unfair tax deduction, and thus, notified the Plaintiff of KRW 108,230,40 for the first period of January 20

(hereinafter “Disposition in this case”). [Grounds for recognition] The Disposition in this case is without dispute, Gap evidence 1, Eul evidence 1 to 4, and the purport of the whole pleadings.

2. Whether the disposition is lawful;

A. 1) Facts of recognition

(2) On December 23, 2009, upon receipt of a tobacco production facility from C (B representative), the Plaintiff agreed to convert the total amount of KRW 640 million into the investment amount of the company run by D (Paragraph 1), and C agreed to supply the production facility of KRW 200,000 per daily production (Paragraph 2 of the contract). D representative E paid KRW 100,000 to C on December 30, 2009 and January 18, 2010, and C paid KRW 20,000 each amount of annual production facility. On January 26, 2010, the Plaintiff concluded a contract for the establishment of a tobacco plant, and concluded a contract for the establishment of a plant, and the Plaintiff was established to attract foreign customs clearance and foreign investment in the name of D and foreign investment.

(D) The representative E was the Plaintiff’s auditor. On February 10, 2010, the Plaintiff agreed to install a facility of 200,000 square meters of daily production in D.

3 The payment of the price and le-electric supply C returned KRW 200 million to E on February 18, 2010, and the Plaintiff paid KRW 300 million to C on February 18, 2010 and KRW 100 million on March 5, 2010.

On the other hand, on March 4, 2010, C supplied four parts of the tobacco manufacturing base. The export declaration form is written as “Plaintiff”, “B”, and “D”.