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1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
Purport of claim and appeal
The first instance court.
Reasons
1. The court's explanation concerning this part of the reasons for the decision of the court of first instance is the same as the corresponding column among the reasons for the decision of the court of first instance. Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of
2. Whether the disposition is lawful;
A. The Plaintiff’s assertion 1) The Plaintiff visited C’s place of business to check D’s location, employee, and business registration certificate, etc. directly, and purchased the tax invoice from C, and received and paid the goods price. Thus, the instant tax invoice cannot be deemed to be a false tax invoice. 2) Even if the instant tax invoice is a false tax invoice, in light of the aforementioned transaction circumstances, the Plaintiff is a bona fide transaction party with a duty of care.
3) In addition, even if each tax invoice of this case is a tax invoice different from the fact, it is imposed in the case of underreporting the value-added tax by such unlawful means as actively concealing and manipulating evidentiary materials with the knowledge that it is a false tax invoice. The additional tax for unfaithful payment is imposed in the case where the Plaintiff did not pay the value-added tax within the payment period without justifiable grounds. The Plaintiff did not know that each of the tax invoices of this case was different from the fact, and there are justifiable grounds for not knowing that the disposition of this case was unlawful and revoked.
B. It is as stated in the attached Form of the relevant statutes.
C. (1) Determination 1) Whether each of the instant dispositions is a tax invoice different from the fact, (1) whether the input tax deduction for the tax invoice received in the course of transaction is denied is stipulated in Article 17(2)1-2 of the former Value-Added Tax Act (amended by Act No. 9617, Apr. 1, 2009).