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1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
Reasons
1. Details of the disposition;
A. On April 20, 2005, the Plaintiff received purchase tax invoices amounting to KRW 1,815,430,000 (hereinafter “instant purchase tax invoices”) from Company B (hereinafter “B”) during the period of value-added tax from the second to the first period of the Value-Added Tax (hereinafter “B”), and issued sales tax invoices amounting to approximately KRW 1,945,370,000 (hereinafter “instant sales tax invoices”) to Company C (hereinafter “C”) and Edio (hereinafter “Edio”).
(hereinafter referred to as the “instant transaction” in relation to the purchase and sale tax invoice of this case
As a result of the investigation conducted in relation to transaction order for computer parts, etc. between Plaintiffs B, C, and Edio during the first taxable period in 2013, the head of the Yangcheon District Tax Office notified the Defendant of the taxation data by deeming that the purchase and sale tax invoice in this case was received through circulation transaction without real transaction. Accordingly, the Defendant determined that the purchase and sale tax invoice in this case was not a real transaction and reduced the purchase and sale tax amount by determining it as a different tax invoice from the fact that it was not a real transaction. On the other hand, the Defendant applied additional tax on the receipt of the purchase and sale tax invoice in this case under Article 22(3) of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013; hereinafter the same shall apply) to the Plaintiff on February 1, 2014.
(hereinafter “instant disposition”). Specific details of the rectification of the amount of purchase and sale tax are as follows, and the instant disposition is the entire penalty tax.
The output tax amount of 120,772,143 78,226,687 245,207,980,901,414 input tax amount of 330,611,978 289,702,888 243,548,04219,418,418,042 reduction -209,839,839,835 -211,476, 201,659.