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1. Value-added tax imposed on the Plaintiff on June 16, 2015 by the Defendant on the second term of two years, 109,248,948 won, and the first term of one year, 2014, and 98,918.
Reasons
1. Details of the disposition;
가. 원고는 에스케이텔레콤 주식회사로부터 이동통신용역 가입자 유치업무 및 관리업무 등을 위탁받고, 에스케이네트웍스 주식회사 등으로부터 외상으로 매입한 휴대전화 단말기를 이동통신 가입자에게 할부로 판매하여 왔다.
From 2010 to 2014, the Plaintiff paid the subsidy to the subscriber by way of paying the subscription fee for communication, the USIM card fee, and the number mobile fee to the subscriber to pay the subscriber's subscription fee.
B. The Plaintiff reported and paid value-added tax from January 2010 to February 2, 2014, and deducted the Plaintiff from the mobile phone sales to the mobile phone sales that the Plaintiff paid.
C. The Defendant, on June 16, 2015, deemed that the Plaintiff’s subscription fees, etc. for mobile communications paid to the Plaintiff is not subject to deduction from the tax base for the mobile communications supply transaction, and concluded that the Plaintiff’s total of KRW 175,354,60 for the first term in 2010, KRW 205,90,920 for the second term in 2010, KRW 190,894,360 for the first term in 2011, KRW 174,607, KRW 720 for the second term in 201, KRW 310,731,470 for the first term in 2012, KRW 451,463,00 for the second term in 2012, KRW 194, value-added tax170 for the first term in 2013, KRW 194, KRW 170 for the second term in 2013, KRW 1314 for the second term in 201.
(hereinafter referred to as “instant disposition”) the remainder after cancellation as described in subsection (e) below is D.
On September 11, 2015, the Plaintiff appealed and filed an appeal with the Tax Tribunal on September 11, 2015, and on December 2, 2012, 2014, the Plaintiff from the Tax Tribunal, on August 6, 2013, with respect to the question of the tax office in which the Value-Added Tax System and the Value-Added Tax System of the Ministry of Strategy and Finance are provided by the agency in cash with part of the installment sales amount in selling the devices purchased from the mobile communications company to the customer by installment contract.