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(영문) 서울행정법원 2019.11.08 2019구합56951
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

C (Representative D; hereinafter referred to as “C”) was established for the purpose of wholesale and retail business of computer peripheral devices on September 4, 2006, and was closed on March 30, 2012 in Yongsan-gu Seoul Metropolitan Government E and FhoG, and the Plaintiff was established on January 1, 2012, and operated a wholesale and retail business of computer peripheral devices in Yongsan-gu Seoul Metropolitan Government E and H.

The head of Seoul Regional Tax Office, including the disposition of imposition against C, means an integrated information system that serves to strengthen the competitiveness of an enterprise by efficiently managing all human and physical resources within an enterprise used for business activities, while conducting the consolidated investigation of corporate tax into Company I (representative J; hereinafter "I") from May 29, 2013 to October 9, 2013.

After confirming that I purchased approximately KRW 1.2 billion from 201 to 2012 products, such as computer peripheral devices, from the company "K" (hereinafter "K"), at the head of the purchase ledger prepared through the system (hereinafter "the head of the purchase ledger of this case"), K listed in the head of the purchase ledger of this case refers to C, and at that time notified the Defendant of taxation data.

Based on the ledger of purchase of this case, the defendant from May 15, 2016 to the same year.

8.3. After conducting the investigation of C and I related persons (hereinafter “the primary investigation of this case”), C was found to have omitted sales of KRW 1,198,926,910 (the total amount entered in the cash settlement in the ledger for purchase of this case) from 2011 to 2012, and C was found to have made a correction and notification of the corporate tax and value-added tax as stated in C’s first disposition column as below.

(hereinafter referred to as “the primary disposition against C”). The same disposition as the primary (original) corporate tax (including additional tax) on August 1, 2016 for the business year (taxable period) of the date of the disposition of tax items. The same disposition is identical to the primary disposition on August 1, 2016.

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