1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. Details of the disposition;

A. The Plaintiff is a company that runs wholesale and retail business, including scrap iron, using 799 as the place of business in the Gwanak-gu Kim Young-si, Kim Young-si. A tax invoice was issued by B (the supply price of KRW 115,101,00, value-added tax amount of KRW 11,510,100, and KRW 11,510,100; hereinafter “instant tax invoice”) in the taxable period of value-added tax for the first quarter of year, 201, after deducting the input tax amount of KRW 11,510,100 from the output tax amount, and filed a tax amount payable for value-added tax for the first year, including the said input tax amount, in deductible expenses, and filed a tax return for the corporate tax for the year 2011.

B. The Busan regional tax office conducted a tax investigation with A from September 15, 201 to November 8, 2011, deeming that the instant tax invoice was a processing tax invoice issued without real transaction, and notified the Defendant of such taxation data.

Based on the foregoing taxation data, the Defendant determined that the supplier, who is a requisite entry item of the instant tax invoice, entered the relevant input tax amount differently from the fact, and subsequently notified the Plaintiff of the correction of KRW 19,438,210 and the additional tax amount of KRW 2,532,220 for the first period of June 1, 201, by allowing the Plaintiff to deduct the relevant input tax amount and to impose the additional tax following the collection of documentary evidence for expenditure (hereinafter “instant disposition”).

C. On November 2, 2012, the Plaintiff dissatisfied with the instant disposition, filed an appeal with the Tax Tribunal, and the Tax Tribunal dismissed the Plaintiff’s appeal on June 5, 2013.

【Ground of recognition】 The fact that there has been no dispute, Gap’s 1 through 4, 10 evidence, Eul’s 1, 2, 3 evidence, Eul’s 4-1 and 2, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. At the time of the Plaintiff’s assertion 1’s transaction with A, the Plaintiff was unaware of the fact that the Plaintiff was a disguised business entity at the time of the transaction with A, G, and the Defendant did not know of the fact that the transaction was conducted with A and G, as alleged by the Defendant.

(b).