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1. Of the instant lawsuit, the Defendant’s value-added tax of KRW 893,700 on April 1, 2015 against the Plaintiff on April 1, 2015.
Reasons
1. Details of the disposition;
A. On December 3, 2011, the Plaintiff awarded a contract for the construction cost of KRW 14,300,000 (i.e., value KRW 13,000,000, value-added tax of KRW 13,000,000) to the Young-gun Construction Work for the second floor of the building on the ground (hereinafter “Yongsi-gun”) on the second floor of the building on the ground (hereinafter “instant construction work”). On December 26, 201, the Plaintiff paid all the said construction cost on December 31, 201. The construction work of this case was completed on December 31, 2011.
B. On December 27, 2011, the Plaintiff issued a purchase tax invoice of KRW 7,00,000,000, which was paid for the instant construction cost, and subsequently filed an input tax return of KRW 700,000,000 from the output tax amount. On June 13, 2012, the Plaintiff received a purchase tax invoice of KRW 6,000,000 (hereinafter “instant tax invoice”) and filed a return of KRW 600,000,000 from the output tax amount, thereby deducting the input tax amount of KRW 600,000 from the output tax amount, and filed a return of the first half-year value tax in 2012.
C. On April 1, 2015, the Defendant notified the Plaintiff of the rectification of the amount of KRW 600,000,000 under the instant tax invoice, on the ground that “The time when the instant construction was confirmed was 2, 2011,” the Defendant did not deduct the amount of KRW 600,000 from the amount of the first output tax for the year 2012, but would have to deduct it from the amount of the second output tax for the year 2011” (i.e., the principal tax amount of KRW 60,000, KRW 293,700).
(hereinafter referred to as “previous Disposition”). D.
On April 16, 2015, the Plaintiff filed an objection seeking revocation of the previous disposition with the Defendant, but the said objection was dismissed on May 15, 2015.
On June 2, 2015, the Plaintiff filed a request for review seeking revocation of the previous disposition with the Commissioner of the National Tax Service, and the Commissioner of the National Tax Service, on June 17, 2015, rendered a decision that the amount of assessment would be corrected to KRW 600,000, by reducing penalty tax of KRW 293,700.
E. On June 24, 2015, the Defendant imposed the Plaintiff on the Plaintiff according to the said decision by the Commissioner of the National Tax Service, KRW 893,700 for value-added tax for the first year, 2012.