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Reasons
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(영문) 서울행정법원 2016.04.14 2015구합71402
법인세부과처분취소
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1. The plaintiff's claim is dismissed.

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

Reasons

1. Details of the disposition;

A. As a result of the consolidated investigation of corporate tax for the business year from May 14, 2014 to August 20, 2014 with respect to the Plaintiff (hereinafter “instant tax investigation”), the director of the Central Regional Tax Office (hereinafter “the Director of the Regional Tax Office”) confirmed the existence of under-reported income of KRW 973,163,556 in total as indicated in the following table, and notified the Defendant thereof.

(Unit) Classification 2007 2008 2009 2010 201 201 201 70,630,630,630,780 69,780,000 541,1041,066,066,700 3,000 36,500,5000 86,5000 81,3500 81,350,36368,7967,796368,7968,79,700 -6367,967,47,967,967,639,675,79,700 -6396,75,79,767,967,947,67,967,639,75,67,639,740,67,947,65,639,67,647,69,7

B. The amount indicated in the above table as “processing Purchase” is divided by transaction partners as follows.

(units: 169,65,90 BD 143,245,00 B E F 169,665,90 B G H 21,050,000 I JK 61,490,000 L M N 145,654,000 L 541,104,90

C. On December 1, 2014, the Defendant notified the Plaintiff of the rectification of corporate tax and value-added tax as indicated below.

(hereinafter “instant disposition”). (Unit: 68,60,530 208 141,564,560 2008 2008 141,564,560 2009 68,782,280 2010 47,166,610 326,113,980 value-added tax on January 30, 2008 30,286,130 10,963,480 27,614,960 on February 2, 2008, 2009, 10,963,480 on January 2, 2009, 3,670,50, 50 202,492,490 202,4602,202,707,8168,680,610

D. On February 26, 2015, the Plaintiff dissatisfied with the instant disposition, filed an appeal with the Tax Tribunal on February 26, 2015, but was dismissed on May 29, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, Eul evidence Nos. 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion first, even before the instant tax investigation, the Defendant against the Plaintiff from December 13, 201 to January 8, 2011.

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