1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1...

1. The reasoning of the judgment of the court of first instance is as stated in Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act, except for the dismissal or addition of the following among the reasoning of the judgment of the court of first instance. Thus, the reasoning of the judgment of the court of first instance is cited in accordance with Article 8(2)

The 8th 16th am “Non-existent” means that “The difference between the purchase amount and the sales amount of each individual taxable period, such as non-existent, is significant, and the Plaintiff is up to the sales amount in B even though there is no purchase amount from KTN in 2008, and as alleged by the Defendant, it is difficult to deem the transaction between the above companies as a processed circulation transaction solely on the grounds that the purchase amount and the sales amount of the entire taxable period are similar.”

The following parts shall be added to 10 ...... 6 ...............

At the time of the investigation by the Investigative Agency, D only stated to the effect that “(a) part of the instant transactions is real transactions and certain of them cannot be specified in the time and amount of false transactions,” the following parts shall be added to 13, following the 10th 13th 10th 13th 10.

Even if KTN did not object to the penalty tax imposed in relation to the instant transaction, as alleged by the Defendant, as stated in the evidence Nos. 18 and 19, it is difficult to view that the imposition of penalty tax on KTN is identical to the fact that the Plaintiff was subject to the imposition of penalty tax (in 2008, even if there was no transaction between the Plaintiff and KTN, it is unclear whether KTN recognizes any transaction in the instant transaction as a processing transaction and imposes penalty tax as a result of the imposition of penalty tax for the taxable year of 2008), and the imposition of penalty tax on KTN, etc. with regard to the instant transaction cannot be deemed as a processing transaction.

“A family member is in the instant transaction.”