1. On December 11, 2014, the Defendant reverted to the Plaintiff’s global income tax of KRW 19,051,810 and KRW 2011.

1. Details of the disposition;

A. The Plaintiff received 15 copies of purchase tax invoices of KRW 137,594,250 (hereinafter “instant tax invoice”) from “E” located in Gangseo-gu Busan Metropolitan City from “E (Representative F)” in 2010 to “E” in the name of “C” in Gangseo-gu Busan Metropolitan City, and deducted the amount as input tax when filing a value-added tax return, while including the purchase amount as necessary expenses when filing a global income tax return for 2010 and 2011.

B. As a result of the investigation into trade order related to E, the Defendant confirmed E’s fake tax invoices seller and accused E to the prosecution. On June 3, 2013, the Defendant issued a revised notice of the total value-added tax amounting to KRW 20,861,530 ( KRW 20,791,930, KRW 12,069,600 in 2010) to the Plaintiff on June 3, 2013 after deducting the input tax amount on the instant tax invoice.

C. In addition, on December 17, 2014, the Defendant notified the Plaintiff of the correction of the total amount of KRW 48,921,780 ( KRW 19,051,814 reverted to year 2010, KRW 29,660,115 reverted to year 201) of global income tax from 2010 to 2011.

(hereinafter “instant disposition”) D.

The plaintiff appealed and filed an appeal with the Tax Tribunal, but was dismissed on March 10, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 and 7, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s alleged E’s actual business operator is not F, a representative of business registration, but G, and the actual supplier of scrap metal is G. The Plaintiff actually purchased scrap metal from G and paid all the proceeds thereof to the head of the Tong. In addition, the purchase of scrap metal itself exists, and the ratio of the tax base against the global income tax in 2010 and 2011 is not consistent with the substance.

Even if the purchase of the above scrap metal by the plaintiff is a processing purchase, it is necessary.