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1. The Defendant’s penalty tax of KRW 181,054,320 on March 14, 2013 for the second term portion of value-added tax for the Plaintiff on March 14, 2013, KRW 88,234,328.
Reasons
1. Details of the disposition;
A. The Plaintiff is a company that was established around August 18, 1986 and runs the non-ferrous metal manufacturing business, etc. with its main office located in Gangnam-gu Seoul Metropolitan Government B and fourth floor and its main office located in Ansan-si C.
- 1,367,15,00 won 2,817,125,000 won -- 123,205,200 won in total of 928,200,810,000 won in the second half period in 2010 for the second period in 2010 for the second period in 2010 : 928,200,200 won in total of 521,810,000 won in 1,490,320,000 won in the second period in 200 for the second period in 209
B. The Plaintiff received purchase tax invoices of KRW 2,940,330,000 (hereinafter “each of the instant purchase tax invoices”) from D (representative E) and F (representative G) in the second and second taxable periods of 2009 and 2010, and filed a value-added tax return by deducting the input tax amount from the output tax amount.
(hereinafter referred to as the "Purchasers of this case" in total of D and F.
As a result of the tax investigation conducted with the Plaintiff from January 14, 2013 to March 4, 2013, the director of the Central Regional Tax Office of China: (a) determined that the actual purchase price is different from the fact, and notified the Defendant of this fact as taxation data.
Accordingly, on March 14, 2013, the Defendant denied the tax base deduction of the input tax amount based on each purchase tax invoice of this case and increased the tax base amount by denying the tax base deduction, and rendered a false decision to collect the additional tax on the input tax amount of each purchase tax invoice of this case as above, and rendered a correction and imposition of value-added tax for the second period portion of value-added tax (including the additional tax of KRW 88,234,328), value-added tax for the first period of 2009 on the Plaintiff on March 14, 2010 (including the additional tax of KRW 46,582,215), for the second period of 2010 (including the additional tax of KRW 46,582,215), and for the second period of 276,489,870 (including the additional tax of KRW 127,457,879) (hereinafter collectively referred to as the “instant disposition”).
The Plaintiff appealed and filed a petition with the Tax Tribunal on May 5, 2013, but on June 5, 2014.