1. The Defendant’s value-added tax on February 7, 2012 787,512,000 (including additional tax of KRW 219,012,00) that was paid to the Plaintiff on February 7, 2012.

1. Details of the disposition;

A. On September 17, 2009, the Plaintiff, a corporation engaged in the manufacturing and construction business, entered into a construction contract with the Mine Energy Development Co., Ltd. (hereinafter “Mining Energy”) to supply solar power generation facilities to 5,700,000,000 won (value-added tax separately) on the optical Energy.

(hereinafter “instant construction project,” b)

On July 7, 2010, the Plaintiff issued a tax invoice of KRW 5,700,000 (hereinafter “instant tax invoice”) for supply value to light energy, and filed a return and payment of value-added tax as included in the value-added tax base for the second period of 2010. In the second taxable period of 2010, the Plaintiff filed a preliminary return of value-added tax equivalent to the instant tax invoice as the input tax amount.

C. From November 15, 2010 to November 19, 2010, the head of the Gu-U.S. Tax Office confirmed on the spot of refund of optical energy. On November 21, 2009, the date when the luminous energy was determined by the Korea Electrical Safety Corporation as the completion date of the construction of solar power generation facilities, deeming the luminous energy as the completion date of the provision of services and determined on November 21, 2009 the supply value of the instant tax invoice as the amount equivalent to the supply value of the luminous energy, and notified the Defendant of the determination as the assessment data.

Accordingly, on November 21, 2009, when the time of supply for the service under the contract of this case was determined and notified the Plaintiff of KRW 513,00,00,000 of the value-added tax for the second period of February 14, 2010 (the imposition of KRW 57,00,000,000 on the additional tax for the second period of value-added tax in 2009 (the additional tax for the failure to enter the tax invoice), and the amount of KRW 867,369,000 (the additional tax for the failure to enter the tax invoice 114,00,000, the additional tax for underreporting 57,000,000, the additional tax for unfaithful return 57,000,000, the additional tax for unfaithful return 126,369,000, and hereinafter referred to as the “instant disposition”).

On November 23, 2012, the Plaintiff appealed and filed a request for a trial with the Tax Tribunal.