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 is a corporation that runs the business of manufacturing and selling clothes.

B. The Plaintiff imported 133,192 punishment (hereinafter “instant goods”) from August 2, 2010 to November 9, 2012, 201, on a 27 occasions, a male-processed in China (hereinafter “instant goods”), and made an import declaration on the instant goods by acting as an agent for a stock company B (representative C; hereinafter “B”) and filed an import declaration on the instant goods under the name of the person liable for duty payment, including Import Declaration D ( August 2, 2010).

C. As a result of the investigation of the import declaration filed by B at the time of the above import declaration, the Plaintiff and B’s production status (2010 F/W production status, 201 S/S production status, 2012 S/S production status) and documents such as seals issued by China, the Defendant found that the actual transaction price of the instant goods was under-reported as KRW 163,860,918 in each of the instant import declaration amounts to KRW 163,860,918 in fact, and on January 22, 2014, the Defendant found that the actual transaction price of the instant goods was under-reported as KRW 16,66,50 in value-added tax on KRW 16,66,50 in value-added tax on KRW 282,0,050 in value-added tax on KRW 14,871,91,2786,50 in value-added tax on KRW 50,350 in value-added tax on KRW 14050,650

(hereinafter “instant No. 1 Disposition”) D.

From February 4, 2014 to August 5, 2014, the Plaintiff paid the total amount of KRW 500,955,520 on three occasions, and applied for the issuance of revised import tax invoices for value-added tax amounting to KRW 28,564,190 (paid number F) paid to the Defendant on February 4, 2014.

E. On February 26, 2014, the Defendant refused to issue revised import tax invoices to the Plaintiff pursuant to Article 35(2)2 of the Value-Added Tax Act (amended by Act No. 11944, Jul. 26, 2013; hereinafter “Revised Value-Added Tax Act”) and Article 2 of the Addenda thereof, and Article 72(4) of the Enforcement Decree of the Value-Added Tax Act.