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1. Disposition of imposition of KRW 164,372,230, imposed on the Plaintiff on December 1, 2014, of KRW 136,165, which the Defendant imposed on the Plaintiff on December 1, 2013.
Reasons
1. Details of the disposition;
A. The Plaintiff is a company that runs a wholesale and retail business in Ulsan-gu B.
B. When the Plaintiff reported value-added tax from the first half to the second half of 2013, the Plaintiff received 59 copies of the purchase tax invoice equivalent to KRW 3,187,189,000 (hereinafter “instant tax invoice”) from two enterprises (hereinafter “instant purchaser”) as follows, and deducted the said input tax amount from the output tax amount.
The amount of money received (value of supply, unit: original) to be reverted to the purchaser’s status (value of supply) shall be 940,237,000 on March 24, 2013, December 24, 2013, 2013, the date of business opening from the representative of the business owner’s number and the date of business opening, which is 647,85,000 on July 24, 2013.
C. On December 1, 2014, the Defendant: (a) conducted an investigation related to the transaction order with the Plaintiff, reported the instant tax invoice as a false tax invoice different from the fact; (b) calculated the amount of tax without deducting the input tax amount for the instant purchaser; and (c) notified the Plaintiff of the correction of the total value-added tax amount of KRW 544,646,560 (including additional tax)
(hereinafter “instant disposition”). On January 2013, 2013, the Value-Added Tax Correction of KRW 94,015,928 C related to the purchase of KRW 940,237,00 and KRW 1,599,09,097,000 for purchase of KRW 647,85,000 for purchase of KRW 647,85,000 for purchase of KRW 647,85,00 for purchase of KRW 224,69,695,30 for purchase of KRW 18,805,30 for non-issuance of the tax invoice, and additional tax for non-issuance of the tax invoice 18,804,740 for non-issuance of the tax invoice 4,939,061 for non-issuance of the tax invoice 37,609,480 for illegal underreporting 89,878,123,934,206,27384,275,2038
D. The Plaintiff, who was dissatisfied with the instant disposition, filed an appeal with the Tax Tribunal on January 5, 2015, but was dismissed on June 25, 2015.
[Ground for recognition] A.