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(영문) 부산지방법원 2015.03.27 2014구합3427
법인세등부과처분취소
Text

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 Plaintiff’s consolidated investigation of corporate tax from the business year of 2008 to the business year of 2012, the head of Seosan District Tax Office: (a) deemed that the Plaintiff’s tax invoice of KRW 1,121,563,809, excluding KRW 165,000,000, which was determined by the processing transaction among the supply price of KRW 1,286,563,809, excluding KRW 165,000,000, is a different tax invoice (title) from the fact; and (b) notified the Defendant of the relevant taxation data.

B. Accordingly, on September 16, 2013, the Defendant denied the deduction of the pertinent input tax amount and imposed an additional tax for the business year of 2009 with no certificate of disbursement (including additional tax of 44,904,283), included an amount of 105,194,450 (including additional tax of 45,51,761), an amount of 145,09,830 (including additional tax of 44,245,917), and an amount of 83,387,393 (including additional tax of 41,666, 208, 209), including an amount of 209, 209, 2010, 209, 360, 297, 209, 2016, 360, 297, 297, 209, 2096, 2096, 2516, 297, 29616

C. On December 23, 2013, the Plaintiff filed an objection with the Director of the Busan Regional Tax Office, but was dismissed on January 17, 2014. On April 17, 2014, the Plaintiff filed a request for a trial with the Tax Tribunal regarding the tax assessment for the business year 2009 and the business year 2010 among the above tax assessment, and the tax assessment for the second period from the second period from 2009 to 2010 (hereinafter “each taxation in this case”). However, the Plaintiff filed a request for a trial with the Tax Tribunal regarding the tax assessment for the second period from 2

7.25. was dismissed.

[Ground of recognition] Facts without dispute, Gap evidence 1 through 5 (including each number, hereinafter the same shall apply), Eul evidence 1, 8, 10, and 11, and the purport of the whole pleadings

2. The instant disposition is made.

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