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Reasons
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(영문) 서울행정법원 2015.04.17 2014구합72354
가산세부과처분취소청구의 소
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1. The plaintiff's claim is dismissed.

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

Reasons

1. Details of the disposition;

A. On April 1, 2010, the Plaintiff: (a) concluded a contract to enter into a construction agreement, such as a golf course landscaping project, with the total supply price of KRW 10,472,00,000,000, and the completion date of construction as of December 31, 2010; (b) concluded a contract to change the said contract to the total supply price of KRW 8,065,000,000, and the completion date of construction on December 31, 2012; (c) on December 31, 2011, the Plaintiff issued a tax invoice of KRW 10,472,00,00,000 for total supply price of KRW 10,407,000,000 for supply price of KRW 10,407,000,000 for supply price of KRW 200,000,000 for supply price of KRW 300,005,200.

B. On May 23, 201, the Plaintiff entered into a contract for the hotel renovation and repair works with the value of 5,641,00,000 won for supply and value of 5,00,000 won for each week and for the scheduled completion date of works, which was concluded on June 30, 2012, and issued a tax invoice of KRW 3,251,135,40 for the total value of supply until February 21, 2012, the Plaintiff entered into a contract for the change of the supply value of the said contract to KRW 3,929,380,000 on May 31, 201; on December 20, 2012, the Plaintiff changed the supply value of the said contract to KRW 1,539,515,400 for each year; and on June 31, 2012 (i) concluded a contract for change to the supply value of the said contract to KRW 1,539,5130,1500

subsection (1) is referred to as “each revised tax invoice of this case” in this subsection.

(C) The Defendant issued the refund of value-added tax to the Plaintiff. On December 31, 2012, on the ground that the Plaintiff filed an application for refund by filing a final return for the second period of 2012, on the ground that the Plaintiff filed an application for refund by filing a final return for the refund at the second period of 2012, even though the amount should be corrected by the second period of 2010.

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