1. The Defendant’s refusal to refund KRW 29,81,590, which was imposed on the Plaintiff on July 4, 2013 and KRW 65,432, which was imposed on the Plaintiff on July 4, 2012.

1. Details of the disposition;

A. From December 1, 2005, the Plaintiff runs a wholesale and retail business with the trade name “C” in Jongno-gu Seoul Metropolitan Government, Jongno-gu.

The Plaintiff supplied 789,592,075 won food and other goods to diplomatic missions abroad of the Republic of Korea located in Colombia, Macro, Pakistan, Finland, lebane, lebane, the Philippines, Kenya, and Libyia in the second two taxable periods of 2012.

(hereinafter “instant transaction”). (b)

On January 25, 2013, the Plaintiff reported the refund of value-added tax of KRW 29,881,590 to the Defendant on the ground that “the instant transaction is an export transaction to which zero-rate tax is applicable under the Value-Added Tax Act.”

However, on July 4, 2013, the Defendant rejected an application for refund on the ground that “the instant transaction does not constitute export of goods,” and notified the Plaintiff of the correction of the value-added tax of KRW 65,432,440 (including additional tax) for the two years in 2012.

C. The Plaintiff appealed and filed an appeal on September 11, 2013, but was dismissed by the Tax Tribunal on December 4, 2013.

[Ground of recognition] Facts without dispute, Gap evidence 1-1, 2-2, Eul evidence 1-1, the purport of the whole pleadings

2. Where a taxpayer, who is the tax authority of the instant disposition, has omitted or mistakenly filed a tax base return, payable tax amount, or refundable tax amount, and thus a decision of correction to reduce or increase the amount of refundable tax pursuant to Article 21(1) of the Value-Added Tax Act, etc. is rendered, the confirmation of tax liability arising from the initial return cannot be maintained any longer. Therefore, the taxpayer shall file a lawsuit seeking revocation of the decision of correction to be paid the amount of refundable tax originally filed by the said tax authority upon objection to the decision of correction of

(See Supreme Court Decision 200Du7520 Decided October 26, 2001, the Defendant imposed imposition of KRW 65,432,440 on the Ministry of Health and Welfare and the Defendant imposed imposition of KRW 65,432,440 on the Ministry of Health and Welfare in 2012. Accordingly, the Plaintiff’s imposition of KRW 95,314,030.