Seoul Administrative Court 201Guhap40134 (2013.04)

Income accrued for the taxable year originally reported on the date of issuance of the tax invoice and receipt of the price;

On January 10, 2005, a tax invoice related to foreign service was issued on January 10, 2005, and the price was received on January 28, 2005, and there is no evidence to acknowledge it as belonging to the income of 2005.

Article 48 of the Enforcement Decree

2013Nu23098 Revocation of Disposition of Imposing global income tax, etc.

United StatesA

Head of Yeongdeungpo Tax Office

Seoul Administrative Court Decision 2011Guhap40134 decided July 4, 2013

March 21, 2014

April 25, 2014

1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the plaintiff.

The judgment of the first instance shall be revoked. On April 4, 201, the part that the Defendant exceeds the OOO of the global income tax for the Plaintiff in 2005 shall be revoked.

1. Quotation of the reasons for the judgment of the first instance;

This judgment is based on the reasoning of the judgment of the court of first instance, except for dismissal or addition of the following matters, and thus, it is based on Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

(1) The fourth through sixth pages 5 shall be advanced as follows:

"The whole purport of evidence Nos. 3 and 8 is added to the whole purport of the pleadings, 1, 2, and there is no counter-proof. ① The plaintiff entered into a contract for foreign production with BB life on December 31, 2004, with the non-indicted 60,000 copies of the non-indicted 60,000 copies of the non-indicted 4 times until December 31, 2004. ② The "written confirmation of the fact of deposit tally tallying and delivery" issued as of January 10, 2005, stating that the time of delivery of the tax invoice OOOOO members issued as of January 10, 200, as of December 5, 2004, the plaintiff did not present the document of supply for non-indicted 4, 2005, while the plaintiff did not present the document of supply for non-indicted 4, 200, the objective evidence of the non-indicted 15, 2004.

2. Conclusion

Therefore, the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.