Seoul Administrative Court 2008Guhap3310 ( October 22, 2009)

early 208west0292 (2008.05)

The tax base finalized by the report shall not be contested in the disposition of increase or correction.

Although it is argued that the final tax base should be deducted from the tax base due to the processing transaction, it can not be asserted in the increased or decreased disposition.

The contents of the decision shall be the same as attached.

1. The plaintiff's appeal is dismissed.

2. Costs of appeal shall be borne by the Plaintiff.

The judgment of the first instance shall be revoked. The defendant's second-term value-added tax for the first term of October 11, 2007, value-added tax for the second term of 2001, value-added tax for the second term of 201, value-added tax for the second term of 2001, 619,640, value-added tax for the first term of 202, value-added tax for the second term of 5,818,370, value-added tax for the second term of 202, 5,689,610, value-added tax for the first term of 203, 4,959,59,590, value-added tax for the second term of 203, value-added tax for the second term of 5,192,610, value-added tax for the first term of 204, value-added tax for the second term of 204, value-added tax for 540,840,205,3704,27

1. Quotation of judgments of the first instance;

The reasoning for this Court’s explanation concerning this case is as follows: (a) the court’s amendment to “204Du9917” for “204Du917” for “204Du9197” for “204Du9197”; and (b) the reasoning for the judgment of the court of first instance is the same as that for the judgment of the court of first instance, except for the parts added under Article 8(2) of the Administrative Litigation Act and the main text of

2. The judgment added by this Court

The Plaintiff asserts to the effect that the instant taxation disposition was procedural defect made in accordance with unlawful procedures, since the Defendant issued a revised tax accountant’s office and the shopping mall’s association so that the certified tax accountant or the president of the shopping mall’s association, etc. can deliver the revised tax report only to the merchants selected voluntarily, thereby allowing the Plaintiff to become aware of the method of the revised tax return.

Therefore, in full view of the purport of the argument in the testimony of the witness of the trial of the party, the defendant prepared a revised report for each merchant to encourage the merchants belonging to the ○○ Market to submit the revised report for value-added tax, and delivered it to the president or the executive director of the ○○ Market to the individual merchant, in order to encourage the merchants belonging to the ○○ Market to submit the revised report for value-added tax. Despite the above encouragement of the revised report, the ○○ Market merchant's revised report for the following reasons, the plaintiff sent the revised report for each merchant to the ○○ Market merchant's merchant's individual commercial mail again after the revised report for the ○○ Market merchant's revised report for the following reasons: the plaintiff submitted an application for the revised report for the revised report to the defendant in consultation with the president of the ○○ Market Market Co., Ltd., which belongs to the ○○ Market Co., Ltd., and the plaintiff did not have any obligation to provide the revised report for the revised report to the defendant, and thus, the plaintiff did not have any obligation to provide the notified to the defendant.

3.In conclusion

Therefore, the plaintiff's claim shall be dismissed as it is without merit, and the judgment of the court of first instance shall be just and it shall be dismissed as it is so decided as per Disposition.