1. On March 23, 2016, the Defendant sought refund of KRW 2,337,032,910 of the value-added tax for the first time in 2015 against the Plaintiff.

1. Details of the disposition;

A. The Plaintiff is engaged in wholesale and retail business, such as scrap iron and steel scoo in the trade name of “C” in Sil interest city B.

The Plaintiff reported and paid KRW 2,921,924,810 for the first term portion of value-added tax in relation to the said workplace in 2015.

B. On December 1, 2015, the Defendant issued a processing tax invoice to the counterparty regarding the transaction during the first taxable period in 2015 (hereinafter “instant transaction”), as well as each output tax amount and input tax amount, as well as the Plaintiff’s act on data.

The value-added tax of KRW 2,921,924,810 (the amount of the tax shall be less than ten won; hereinafter the same shall apply) that was paid as described in the paragraph shall be 0 won, and the additional tax of KRW 584,891,90 (the amount of the tax shall be less than ten won; hereinafter the same shall apply) was imposed and collected at KRW 584,891,90.

C. On March 23, 2016, the Plaintiff filed a request for correction to the effect that the amount of tax equivalent to the value-added tax already paid by the Plaintiff should be refunded to the Plaintiff (i.e., value-added tax 2,921,924,810 won (i.e., value-added tax paid 2,921,924,81,900 won for non-performance of tax invoices - Penalty Tax 584,891,900 won for non-performance of tax invoices; hereinafter “marketed tax amount”), but the Defendant rendered a disposition rejecting the Plaintiff’s request for correction on March 23, 2016 (hereinafter “instant refusal disposition”).

On December 30, 2015, the Plaintiff’s revocation of the instant disposition and the preliminary disposition by the Tax Tribunal on the grounds that the instant transaction was not the most most active transaction.

Although the Tax Tribunal filed an administrative appeal seeking refund of value-added tax already paid for the same reason as stated in the Paragraph, on December 23, 2016, the said disposition was deemed lawful on the ground that the instant transaction constitutes the most trade and thus, the said disposition was rendered to dismiss the Plaintiff’s claim.

(Case Number: The first instance court 2016J 182, hereinafter referred to as "first instance administrative appeal"). (e)

In addition, the plaintiff on 2016.