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1. The disposition in the attached Table that the Defendant rendered to the Plaintiff on September 1, 2016 shall be revoked.
2. The costs of the lawsuit are assessed against the defendant.
Reasons
1. Details of disposition;
A. The Plaintiff is a company established on August 1, 2007 and manufactured a PVC hosting engineer by July 10, 2014.
B. From the second to the second period of 2008, the Plaintiff received purchase tax invoices of KRW 35,943,00,000 in total from B Co., Ltd. (hereinafter “B”) and C Co., Ltd. (hereinafter “D”), E Co., Ltd. (hereinafter “E”), and F Co., Ltd. (hereinafter “F”), and issued sales tax invoices of KRW 37,370,000 in total of supply values to G Co., Ltd. (hereinafter “G”), H (hereinafter “H”), and D’s supply values (hereinafter collectively including the purchase tax invoices and the sales tax invoices), and filed a return and payment by including the supply value of the instant tax invoices in the input tax amount and the output tax amount for each taxable period.
(unit: 00 million won) G H CF C E
C. From June 14, 2013 to June 6, 2014, the Commissioner of the Busan Regional Tax Office conducted a tax investigation into B and G, and deemed that the Plaintiff participated in the processing transaction between B and G, and notified the Defendant of the taxation data related to the Plaintiff.
From May 2, 2016 to July 31, 2016, the Defendant conducted an investigation into the Plaintiff’s tax offense. From May 2, 2016 to July 31, 2016, deeming the instant tax invoice as a processing tax invoice as indicated in the following table, and rendered a disposition on September 1, 2016 to the Plaintiff listed in the attached list:
(hereinafter referred to as “instant Disposition”) A - B’s strategic transaction (processing 33,11,00,000) - B’s representative director - B’s strategic transaction (processing 33,608,000,000) with H in collusion with the G representative director, who is a subsidiary, by creating items or virtual virtual items which are not valuable for one-time strategic transaction, and giving and receiving false tax invoices (processing 33,608,000,000) - The G representative director J shall, under the direction of B representative director I, receive false tax invoices from the relevant company under the pretext of “ Strategy Transaction” (processing 2,321,000,000) - the processing transaction under the pretext of strategic transaction.