1. On April 1, 2012, the Defendant imposed value-added tax of KRW 2,816,806,440 on the Plaintiff in 2010.

Details of the disposition

The plaintiff was established for the purpose of the same refining business on October 17, 2008 (the location of its head office at the time of its establishment was 450-2, hereinafter referred to as the "Simsan City, Gun), and around December 2008, the plaintiff started the construction of a new factory in 650-3, which is the location of its head office, and completed the construction of a new factory in Yong-gun, Chungcheongnam-gun, Chungcheongnam-gun, the location of its head office as of June 22, 2009, and then moved its head office to the company around June 22, 2009, and from July 2009, the same refining business [the business of producing the waste scrap as a raw material and supplying electric wires to the company].

The Plaintiff received 60 copies of the tax invoice (hereinafter “each of the instant tax invoices”) equivalent to the total supply value of KRW 16,287,31,440 in the first taxable period of the value-added tax for the first taxable period of the value-added tax in 2010 from B which registered the business of the wholesale and retail business of the non-ferrous scrap metal wholesale and retail business, and deducted the input tax amount under each of the instant tax invoices from the output tax amount to the Defendant, and paid the value-added tax for the first taxable year of

However, the director of the Central Regional Tax Office of China denied the deduction of the input tax amount on the ground that the transaction between the Plaintiff and B (A) is a transactional transaction different from the fact, and notified the Plaintiff of the determination of the correction of the purchase tax amount of KRW 2,816,806,40 (including additional tax) on April 1, 2012, on the ground that the transaction between the Plaintiff and B (A) is a transactional transaction, each of the tax invoices of this case received from B (A) in the first VAT taxable period of value added tax in 2010.

(hereinafter referred to as the "disposition of this case"). 【No dispute exists with the ground for recognition, Gap evidence 1 through 3, and Eul evidence 1 (including the Serial number; hereinafter the same shall apply), and the purport of the whole pleadings.