1. The judgment of the court of first instance is modified as follows.

On December 1, 2014, the Defendant, against the Plaintiff, on January 1, 2012.

1. Details of the disposition;

A. From March 13, 2012 to July 2, 2014, the Plaintiff: (a) engaged in the Li Government building B and the non-ferrous metal wholesale business; (b) filed a return on and pays the value-added tax and corporate tax on the basis of each purchase tax invoice (hereinafter collectively referred to as the “instant tax invoice”) worth KRW 43.24 billion in total of the supply values issued from January 2, 2012 to February 2, 2013, including the supply values of KRW 43.265 billion in total of the supply values received during the same period as each purchase tax invoice (hereinafter referred to as the “each of the above sales and purchase tax invoices”).

B. On December 1, 2014, on the ground that all of the instant tax invoices were issued without a real transaction, the Defendant issued the instant disposition against the Plaintiff on December 1, 2012: (a) KRW 341,368,410 (including additional taxes); (b) KRW 525,02,260; (c) KRW 44,40,320; and (d) KRW 429,576,370; and (c) KRW 3,273,970 for corporate tax for the year 2012, as follows.

1. Principal tax and additional tax for the first year of 2012: 341,368,410 won: 16,314,590 won for the principal tax of value-added tax (tax amount refunded exceeding the output tax amount)

(3) Additional tax on an excessive refund declaration amounting to 6,525,830 won (amended by Act No. 14382, Dec. 20, 2016; hereinafter the same shall apply) 6,525,830 won (amended by Act No. 14382, Dec. 2016)

(4) Additional tax for insincere refund in excess: Article 47-4(1)2 of the former Framework Act on National Taxes of KRW 4,204,270; Article 27-4(1)2 of the Enforcement Decree of the Framework Act on National Taxes x 3/10,00 x 859 days (ended days) x 2, 2012: Additional tax for value-added tax for the second year, 525,02, 260 : 536,95,080 26,849,754,00 ,00 13,491,136,00 ,00 ;