1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1..

1. The reasoning of the judgment of this court citing the judgment of the court of first instance is as stated in the reasoning of the judgment of the court of first instance, except for adding the following judgments as to the matters alleged by the defendant in the trial of the court of first instance. Thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and the main text

2. Additional determination

A. As to the assertion that the value-added tax amount constitutes a false statement, the Defendant asserts that the amount of value-added tax should not be deducted as an input tax amount, since all the exporters, such as the Plaintiff, were engaged in the trade of gold bullion from the beginning, and there was no intent to pay the value-added tax, and there was no intention to collect the value-added tax from the counter-party to the transaction. Therefore, even if the tax invoice on which the value-added tax is stated was issued,

However, as acknowledged earlier, each of the tax invoices of this case was received from each of the purchase places of this case after the Plaintiff purchased the gold bullion of this case from each of the purchase places, received the actual gold bullion on the date of purchase, and paid the total amount of the value of supply and the input tax, and then received each of the tax invoices of this case, stating the input tax amount, from each of the purchase places of this case.

Therefore, the defendant's above assertion is without merit.

B. As to the assertion of the principle of good faith, the Defendant asserts that the input tax deduction for the instant tax invoice should not be allowed in accordance with the principle of good faith, since the instant gold bullion transactions abuse the zero tax rate system, by deceiving the national treasury and impairing the foundation of the value-added

In order to apply the principle of good faith to taxpayers, there is an objectively contradictory behavior of taxpayers, and the behavior is very serious for taxpayers.