The judgment below is reversed, and the case is remanded to the Seoul High Court.

The grounds of appeal are examined.

1. The former Value-Added Tax Act, amended by Act No. 9268, Dec. 26, 2008; enacted on January 1, 2010, introduced an electronic tax invoice system for the purpose of reducing excessive tax payment cooperation expenses and tax administration expenses related to value-added tax, which is a method of collecting the transaction, and enhancing transparency in transaction. Accordingly, the current Value-Added Tax Act requires corporate entrepreneurs and individual entrepreneurs prescribed by Presidential Decree to issue electronic tax invoices, and issues electronic tax invoices to the Commissioner of the National Tax Service when he/she issues or issues electronic tax invoices (Article 32(2) and (3)), but the details of issuance may not be submitted to the Commissioner of the National Tax Service by not later than the 11th day of the month following the last day of the taxable period or the preliminary return period in which the relevant goods or services are supplied.

Article 54(2) of the former Enforcement Rule of the Value-Added Tax Act, which was amended on March 26, 2009 and enforced on January 1, 2010, is prescribed (Article 54(2)). In addition, the former Enforcement Rule, which was enforced on January 1, 2010, separates the total amount of sales and purchase tax invoices into the “amount of issuance of electronic tax invoices (receiving)” and “amount of issuance (receiving other than electronic tax invoices)” and “amount of issuance (receiving other than electronic tax invoices)” from the “amount of issuance (receiving other than electronic tax invoices)”, unlike the “amount of receipt (receiving other than electronic tax invoices)”, shall be recorded only in the total number of sales and purchase places, purchase value, and amount of tax, and shall not be included in each essential entry in the aggregate of other tax invoices under the Value-Added Tax Act (Article 54(1) of the same Act) [Attachment 20-21(1) of the Enforcement Rule of the current Act].