The part of the judgment below against the Plaintiff imposing value-added tax is reversed, and this part of the case is applicable.

The grounds of appeal are examined.

1. Plaintiff’s ground of appeal

A. The lower court determined that: (a) based on the evidence adopted by the Plaintiff: (a) the Plaintiff received the purchase tax invoice of KRW 923,565,200 (hereinafter “instant first tax invoice”); (b) the Plaintiff received the purchase tax invoice of KRW 460,597,000 (hereinafter “E”) in the first taxable period of 2011 from E Co., Ltd. (hereinafter “E”); and (c) the Plaintiff received the purchase tax invoice of KRW 460,597,000 (hereinafter “second tax invoice”); and (c) the Plaintiff paid the Defendant the input tax amount related to each of the instant tax invoices to the Defendant for the second period of 2010 and 11, 2011, on the grounds that each of the instant tax invoices constitutes the value-added tax invoice; and (c) in light of the circumstances indicated in its reasoning, the Plaintiff’s return and payment of value-added tax based on the fact that each of the instant tax invoices constitutes an unfair tax return; and (d) the portion of the instant imposition disposition was lawful for the Plaintiff.

The Plaintiff’s ground of appeal that each of the tax invoices of this case does not constitute a false tax invoice among the judgment of the court below is merely an error in the selection of evidence or fact-finding which belong to the exclusive jurisdiction of the court below, and thus cannot be a legitimate ground of appeal. Furthermore, even if examining the judgment of the court below in light of the records, the court below did not err by misapprehending the legal principles on the parties to the contract

However, the lower court determined that the part of the imposition disposition of each value-added tax of this case, except for the unfair under-reported penalty, is lawful, solely based on its stated reasoning.