1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance cited in this case is as stated in the reasoning of the judgment of the court of first instance, in addition to the part added or added below, and thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

The following shall be added at least 5 pages 11 of the judgment of the first instance:

As to this, the plaintiff added the reason that "the actual transaction was made but the actual supplier is different from the supplier of each tax invoice of this case" in the lawsuit of this case even though the disposition of this case was taken on the ground that "each of the tax invoices of this case was received without actual transaction," and the plaintiff asserts that the additional change of the reason for the disposition of this case was not allowed.

Since the subject matter of a taxation disposition lawsuit is objective existence of legitimate tax amount, the tax authority may submit new data, which can support the legitimacy of the tax base and tax amount recognized in the relevant disposition, or exchange and change the reasons within the scope that maintains the identity of the disposition, even though during the lawsuit, until the closing of argument in the fact-finding court. It does not necessarily mean that the tax authority can determine the legitimacy of the disposition only by the data at the time of the disposition, or

(2) The grounds for imposition of value-added tax in the instant case are as follows: (a) inasmuch as the grounds for imposition of value-added tax in the instant case include only the grounds for the non-deduction of the input tax amount on each of the instant tax invoices within the scope of the same tax items, the addition of the grounds for disposition shall be permitted to the extent recognized as identical to the disposition, on the ground that the grounds for imposition of value-added tax in the instant case are different, maintaining the consistency of the disposition, such as “non-deduction of the input tax amount on each of the instant tax invoices” which are the grounds for taxation within the scope of the same tax items.

The plaintiff's assertion is correct.