1. The Defendant’s first period of 73,902,830 won against the Plaintiff on September 1, 2014, the second period of 367,86,230 won in 2012, and the second period of 367,86,230 won in 2013.

1. Details of the disposition;

A. The Plaintiff is a company established around April 201 and engaged in wholesale and retail business at a bank (bank) such as G, which was established around April 201 (in the order of 90% or more).

나. 원고는 2012년 제1기부터 2013년 제2기까지의 부가가치세 과세기간 동안 소외 주식회사 B(이하 ‘B’이라 한다)로부터 은 그래뉼(알갱이)을 매입하면서 공급가액 합계 26,750,000,000원 상당의 매입세금계산서 555매(이하 ‘이 사건 매입세금계산서’라 한다)를 수취하였고, 같은 기간 동안 주식회사 제일금속 등 112개의 매출처에 은 그래뉼을 공급하면서 공급가액 합계 26,953,000,000원 상당의 매출세금계산서 2,349매(이하 ‘이 사건 매출세금계산서’라 하고, 이 사건 매입세금계산서와 합하여 ‘이 사건 매입ㆍ매출세금계산서’라 한다)를 교부하였다

(hereinafter referred to as “the instant purchase and sale transaction” in relation to the purchase and sale tax invoice of this case

From April 24, 2014 to August 10, 2014, the head of the Seoul Regional Tax Office confirmed that the Plaintiff received and issued the purchase and sale tax invoice of this case without real transaction during the period of the value-added tax from the first to the second period of the Value-Added Tax (2013), and notified the Defendant thereof. Accordingly, the Defendant denied the input tax amount on the purchase and sale tax invoice of this case and the output tax amount; on the other hand, the Defendant applied additional tax on the receipt of the purchase and sale tax invoice of this case pursuant to Article 22(3) of the former Value-Added Tax Act (Amended by Act No. 11873, Jun. 7, 2013; Act No. 11873, Sep. 1, 2014; Act No. 367, Jun. 6, 2012; Act No. 2386, Mar. 230, 2012; Act No. 13034, Mar. 15, 2014

(hereinafter collectively referred to as “instant disposition”). D.

The plaintiff is dissatisfied with this and to the Tax Tribunal on November 24, 2014.