1. The Defendant’s rejection disposition against the Plaintiff on June 26, 2013 is revoked.

2. The costs of the lawsuit are assessed against the defendant.

1. Details of the disposition;

A. The Plaintiff, a corporation that operates slaughter business with the head office at Jung-Eup, concurrently operates value-added tax-free business, such as slaughter, processing, and meat sales business purchased by the Plaintiff for sales purposes (hereinafter “self-doing business”), and value-added tax-added tax taxable that provides slaughter and processing services at the commission of another person (hereinafter “entrusted livestock shed”).

B. The Plaintiff filed a return on value-added tax with the Defendant on the basis of the value of supply calculated based on the common input tax amount of KRW 584,191,33 (hereinafter “instant major purchase tax amount”) arising from slaughter, such as welfare expenses, repair expenses, expendable goods, fuel expenses, waste disposal expenses, waste disposal expenses, repair expenses, etc. incurred during the second period from 1 to 2012 (hereinafter “instant major purchase tax amount”).

C. On April 25, 2013, the Plaintiff filed a request for correction seeking refund of KRW 190,334,650 out of the tax amount that was paid by asserting that the method of calculating the calculated tax amount according to the proportion of the supply value of the key purchase tax of the instant case initially reported with respect to the value-added tax of the second period from April 25, 2010 to the value-added tax of the second period is unreasonable.

On June 26, 2013, the Defendant rejected the Plaintiff’s request for correction on the ground that “Article 61(1) of the Enforcement Decree of the Value-Added Tax Act stipulates that the input tax amount related to the tax-free business shall be calculated according to the actual attribution in cases where the entrepreneur concurrently operates the taxable business and the tax-free business, but the common input tax amount, which is commonly used for the taxable business and the tax-free business and is not distinguishable from the actual attribution, shall be calculated in accordance with the ratio of the value of the tax-free supply to the total value of the supplies.”

E. On September 25, 2013, the Plaintiff is dissatisfied with the instant refusal disposition, and the Plaintiff filed an appeal with the Tax Tribunal for adjudication is an error in the classification of major purchase tax amount.