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1. On July 1, 2013, the Defendant imposed a value-added tax of KRW 589,654,920 on the Plaintiff for the second period of 2010.
Reasons
1. Details of the disposition;
A. The Plaintiff, a corporation that was established on July 9, 2001 and runs the same refining and refining, and the non-ferrous metal wholesale business, was issued 81 copies of purchase tax invoices of KRW 10,70,165,230 (excluding the tax invoices issued from No. 10,000 among these corporations) in total from Company B (hereinafter “stock company” in the name of the first taxable period of the value-added tax in 2010) during the first taxable period of the value-added tax in 2010 to the first taxable period of the value-added tax in 2012, and paid the value-added tax from each of the above corporations to the taxable period of the first taxable period of the value-added tax in 2010 to the taxable period of the first taxable period of the value-added tax, and paid the value-added tax from 2010 to 2010 to 2012 by each of the above corporations.
B. As a result of an investigation into trade order with the Plaintiff from November 29, 2012 to May 15, 2013, the Defendant: (a) instead of deducting the above input tax amount on the ground that the Plaintiff’s tax invoice was a tax invoice different from the Plaintiff; (b) on July 1, 2013, by applying the additional tax on non-payment of documentary evidence under Article 76(5) of the Corporate Tax Act (hereinafter “instant disposition”); and (c) on July 1, 2012, the Defendant imposed KRW 418,595,570, and corporate tax of KRW 49,180,000 for the business year 2012.
C. On December 3, 2014, the Plaintiff filed a petition for a trial with the Tax Tribunal. On December 3, 2014, the Tax Tribunal revoked the imposition of KRW 418,595,570 on the first term value-added tax in 2012 related to the transaction with the No. 1 transaction with the No. 418,595,570, and dismissed the remaining request for a trial.