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(영문) 서울고등법원 2014.11.12 2013누26622
법인세등부과처분취소
Text

1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

Reasons

The reasoning of the judgment of this court cited in the first instance court is as follows, and the reasoning of the judgment of the first instance is identical to that of the first instance court, except for the following and the additional determination in the following paragraphs. Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article

3 below the second second judgment of the first instance court, the term “in the first and second taxable periods of 2008” shall be deleted.

The third to fourth to fourth shall be followed by the following:

1) Accordingly, on July 8, 2011, the Defendant imposed corporate tax for the business year 2008 and the business year 2009 and the value-added tax for the taxable period from 2007 to 2009, as indicated in the “Initial Disposition” column in the attached Disposition List on the Plaintiff.

2) On October 6, 2011, the Plaintiff appealed with the Tax Tribunal. On September 12, 2012, the Tax Tribunal rendered a partial decision to the effect that “the purchase of Plaintiff’s own shares does not constitute low price acquisition.” Accordingly, the Defendant issued a revised notice of reduction of KRW 2,603,218,497 out of corporate tax for the business year 2008 as stated in the separate sheet No. 3, the Defendant issued a revised notice of reduction of KRW 2,603,218,497 of corporate tax as stated in the separate sheet No. 408 (hereinafter “attached Form”).

) The 5th 7th 7th eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth e.g., 36 shop occupants, including 18 shop occupants as indicated in the following table, and the Plaintiff

The 6th 11st thm of the judgment of the first instance court is "Article 25" to "Article 25 (1)."

On the 9th day below the judgment of the first instance court, the "corporate passbook and seal imprint" shall be raised to the "corporate passbook".

Whether or not the defendant is a tax invoice different from the facts added, shall be the first instance court, and this court shall also select the subcontractor and directly pay the subcontract price.

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