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(영문) 서울행정법원 2017.09.29 2016구합62870
법인세등부과처분취소
Text

1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Reasons

Details of the disposition

The Debtor Rehabilitation Debtor Co., Ltd. established on March 23, 1993 and operated a real estate leasing business, etc., and established C (C; hereinafter referred to as "C") with an overseas point in the Philippines detailed on January 31, 2012, and through C, it refers to a clean brut ste which is compressedly processed in the shape of a raw pole within 40 meters in length after it was made from a corporation located in Vietnam with friendly forestry wastes or timbering trees, etc. using a bulver.

B, upon receipt of the decision on May 10, 2016, the Seoul Central District Court decided to commence rehabilitation proceedings (2016 Gohap10049) and appointed B as a custodian.

(1) The Seoul Regional Tax Office denied the deduction of the corporate tax and the input tax deduction of the amount equivalent to the above difference on the ground that the Plaintiff’s purchase cost of Dolet was uneasinessd Co., Ltd. (hereinafter “D”), E Co., Ltd. (hereinafter “E”), and F Co., Ltd. (hereinafter “affiliated companies”), and the Plaintiff’s representative director’s tax deduction of the corporate tax and the input tax deduction of the amount equivalent to the above difference on October 12, 2015, on the ground that the Plaintiff conducted an integrated investigation of corporate tax against the Plaintiff from July 1, 2015 to October 15, 2015, the Seoul Regional Tax Office denied the deduction of the corporate tax and the amount of the input tax deduction of the corporate tax for the corporate tax for the business year 181,580,373 (including additional tax), the corporate tax for the business year 168, the value-added tax for the business year 2014, the value-added tax for the value-added tax for the business year 2075, 2714,2717

(2) On December 31, 2015, the Plaintiff filed a petition for review with the Commissioner of the National Tax Service on December 31, 2015, but was dismissed on February 12, 2016.

[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 1 through 4, Eul evidence Nos. 1, 2, and 3 (including each number), and the purport of the entire pleading is legitimate.

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