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(영문) 울산지방법원 2018.04.26 2017구합6895
법인세부과처분등취소
Text

1. All of the plaintiff's claims are dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Reasons

1. Details of the disposition;

A. The Plaintiff is a stock company established around July 15, 1994 for the operation of automobile parts manufacturing business, etc.

B. In the business year 2011, the Plaintiff appropriated total of KRW 950,000,000 in total for processing costs, such as raw materials, on 154 occasions as indicated below (hereinafter “instant processing costs”), and appropriated the total of KRW 950,00,000 in total for principal and short-term loans, which are the representative of each corresponding account, as follows:

(hereinafter) The amount of money collected from the Account (unit: the cost of printing books) 51,737,50 travel expenses, 1236,290,830 travel expenses, transportation expenses, transportation expenses (boards), 615,616,200 raw material expenses (boards) 6865,00,000 vehicle maintenance expenses (boards) 59,580,419,000 overseas installation expenses (boards) 13219,356,470 Tax Tribunal's decision on July 25, 2017 (units: KRW 7), and the complaint (boards. 3) of this case (boards. 219,364,470) are written as follows; however, it is clear that all of the records of this case are written as follows:

Total 154 950,000,000

C. As of December 31, 201, KRW 136,933,847, out of the provisional receipts received by the representative of the instant case, was disposed of, and the balance of the provisional receipts became KRW 813,066,153 (hereinafter “the balance of the provisional receipts”).

On August 23, 2013, the Plaintiff received a notice of submission of corporate tax explanatory data and of revised return from the Defendant on November 4, 2013, and returned and paid corporate tax of KRW 230,071,810 as a non-deductible of the processing cost of the instant case on November 4, 2013, and accordingly, disposed of the said KRW 136,93,847 as bonus, and the remaining amount of KRW 813,06,153 as a bonus, respectively.

E. The plaintiff is above D.

In handling the same as the entry in the paragraph, the accounting was made as follows.

In other words, the balance of the instant provisional deposit is included in the Plaintiff’s debt balance sheet in the business year 2011, but it appears that it was replaced by the carried-over earned surplus in the business year 2013.

the decrease in the occurrence of the business year;

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