1. All appeals filed by the Plaintiff (Counterclaim Defendant) and the Defendant (Counterclaim Plaintiff) are dismissed.

2. The costs of appeal shall be borne respectively by each party.

1. Basic facts

A. 1) Party A is a company mainly engaged in the development, sale, and distribution of mobile tax base, and G (at present, the representative director of the Plaintiff) who is a group E chairperson or F.

(i) this corporation was the actual inspection of the corporation, and by up to 2012, the only H mobile SP Partners program (I) in the Republic of Korea is almost the only H mobile set;

I. The system is to certify that the design and quality of H mobile phones developed by small and medium enterprises passed the reliability test established by H.

As a certification company, he/she has the right to manufacture and sell the mobile phone royalty in fact exclusively with H's certification.

2) J Co., Ltd. (hereinafter “J”)

(3) On the other hand, A was merged with the Plaintiff on December 15, 2015 during the instant lawsuit, and the Plaintiff took over the litigation procedures. In addition, A was merged with the Plaintiff on December 15, 2015.

B. A) In order to increase their annual sales around 2012, a sales officer of A requested J to issue a marina license tax invoice at the end of the year after issuing the processing tax invoice at the J’s end, and then cancel the sales in the form of return processing in the next year. (2) However, at the time, J was no significant amount of sales, and thus, the Defendant would be issued a processing tax invoice by A on behalf of J.

On December 31, 2012, A issued two copies of the tax invoice stating that “A sells goods of KRW 276,298,008 (value 25,118,008 value-added tax (value 25,108 value-added tax) and the aggregate amount of KRW 77,164,244 (value 70,149,312 value-added tax (value 70,149,314,932) to the Defendant” (hereinafter “instant tax invoice”), and accordingly, the Defendant filed a value-added tax return reflecting this.